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Documents citing Commissioner Of Income Tax vs M/S.Pallava Granite Industries (I) Pvt on 19 November, 2013

The Commissioner Of Income Tax vs M/S.Cauvery Enterprises on 5 August, 2021

9.The decision in the case of Arihant Tiles & Marbles (P) Ltd. (supra) would also aid the case of the assessee, wherein, the Court pointed out that it was not concerned only with cutting of marble blocks into slabs, but also concerned with the activity of polishing and ultimate conversion of blocks into polished slabs and tiles and the processes/activities undertaken by the assessee in various stages through which the blocks had to go through before they become polished slabs and tiles, undoubtedly constitute the activity of manufacture or production.
Madras High Court Cites 12 - Cited by 0 - Full Document

Jewels Magnum, Coimbatore vs Assessee on 19 February, 2016

According to the Ld. representative, the gold bar undergoes different processes before becoming the final production, namely, gold medallion/gold pendant. Referring to the quantity of gold bar imported and its value, the Ld. representative submitted that the assessee has made substantial export and earned foreign exchange. During the assessment year 2011-12, the assessee has earned `27.82 Crores and for the assessment year 2012-13, the assessee has earned `38.81 Crores. Referring to the judgment of Madras High Court in CIT v. Pallava Granite Industries (I)(P.) Ltd. 5 I.T.A. Nos.2311 & 2312/Mds/15 (2014) 42 taxmann.com 102, the Ld. representative submitted that 'manufacture' would include every process, which ultimately results in production of new article having a different character. Ultimately, the High Court found that cutting and polishing of granite slabs would amount to manufacture or production of an article or thing and hence it is eligible for exemption. Referring to the definition in Special Economic Zone Act, 2005, the Ld. representative submitted that 'manufacture' means to make, produce, fabricate, assemble, process or bring into existence, by hand or by machine, a new product having a distinctive name, character or use and shall include process such as refrigeration, cutting, polishing, blending etc. Since the gold bar imported by the assessee undergoes a series of process before it reaches the final stage as gold medallion/ gold pendant, according to the Ld. representative, the end product manufactured by the assessee, namely, gold medallion / gold pendant has to be treated as a new article. Referring to the assessment order, the Ld. representative submitted that the assessee manufactured gold medallions. Special Economic Zone authorizes the assessee to manufacture only gold bangles and gold pendants. In violation of approval granted by Special Economic Zone, according to the Ld. representative, the Assessing Officer 6 I.T.A. Nos.2311 & 2312/Mds/15 found that the assessee has manufactured gold medallions. According to the Ld. representative, what was manufactured by the assessee is only gold pendants and not medallions. Referring to the dictionary meaning of the word "medallion" in Concise Oxford English Dictionary, Twelfth Edition, the Ld. representative submitted that "medallion" means a piece of jewellery in the shape of a medal, worn as a pendant. Therefore, the medallion is nothing but a product of jewellery which would be worn as pendant. Therefore, medallion is a species and pendant genesis. "Pendant", according to the Ld. representative, is also called as medallion. The term "pendant" is carried in its definition to include medallion even in the technical sense.
Income Tax Appellate Tribunal - Chennai Cites 10 - Cited by 0 - Full Document
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