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Commissioner Of Income-Tax vs Relish Foods on 16 March, 1989

Likewise, in the case of CIT v. Relish Food with respect to deduction u/s 80HH, the assessee was engaged in peeling and freezing of shrimps. Since there was no essential difference between raw shrimps and frozen shrimps it was held that the assessee 9 was not entitled to special deduction. In the case of Aqua Minerals Private Limited for the production of demineralised water it was held that there is no manufacturing within the meaning of section 80I. Likewise in the DXN Herbal Mfg. (India) (P) Limited, filing of mushroom power in gelatin capsules to make it fit for marketing it was held that it is merely a process which does not amount to manufacture or production of any commercially distinct commodity so as to fulfill conditions stipulated u/s 80IB of the Act.

Income Tax Officer vs Prakashchand Soni [Alongwith Ita Nos. ... on 30 July, 2004

3. On the other hand, the crux of arguments on behalf of the assessee is that a highly specialized process with the aid of machinery is involved for manufacturing of Dal out of gram, moong, urad, masur, etc. as commercially new and distinct end product comes into existence. The ld. Counsel for the assessee also invited our attention to the process involved for which our attention was invited to page 3 (para D) of the impugned order. The ld. Counsel for the assessee also relied 3 upon the cases which have been dealt with in the impugned order especially pages 5 to 7. Further reliance was placed upon the decision in ITO v. Arihant Tiles & Marbles Private Limited; 320 ITR 79 (SC), CIT v. Oracle Software India Limited (2010) 320 IR 546 (SC) along with the decision of the Tribunal in the case of ITO v. Kamal Kumar Agrawal (ITA No. 170/Ind/2003) and ITA No. 4/Ind/2006 order dated June 8, 2007.
Income Tax Appellate Tribunal - Indore Cites 1 - Cited by 14 - Full Document

Cit vs Sesa Goa Ltd. on 17 November, 2004

8. In later decision the Hon'ble Apex Court in Arihant Tiles & Marbles Private Limited (2010) 320 ITR 79 (SC) order dated 2nd December, 2009, Sawing Marble Blocks into slabs and tiles and polishing it was held that it amounts to manufacture or production within the meaning of section 80IA(2)(iii) of the Act. It is pertinent to mention here that while coming to this conclusion, the Hon'ble Apex Court applied the decision pronounced in CIT v. Ses Goa Limited; 271 ITR 331 (SC) and CIT v. N.C. Budhiraja & Company; 204 ITR 412 (SC) and distinguished the decision in Rajasthan State Electricity Board v. Associated Stone Industries (2000) AIR 2000 SC 2382 and Aman Marble Industries Private Limited Vs. Collector of Central Excise (20030 157 ELT 393 (SC) and affirmed the decision from Hon'ble Rajasthan High Court in Arihant Tiles & Marbles Private Limited vs. ITO; 295 ITR 148.
Supreme Court of India Cites 17 - Cited by 138 - Full Document

Raiasthan Stat Eelectricity Board vs Associated Stone Industries & Anr on 8 May, 2000

8. In later decision the Hon'ble Apex Court in Arihant Tiles & Marbles Private Limited (2010) 320 ITR 79 (SC) order dated 2nd December, 2009, Sawing Marble Blocks into slabs and tiles and polishing it was held that it amounts to manufacture or production within the meaning of section 80IA(2)(iii) of the Act. It is pertinent to mention here that while coming to this conclusion, the Hon'ble Apex Court applied the decision pronounced in CIT v. Ses Goa Limited; 271 ITR 331 (SC) and CIT v. N.C. Budhiraja & Company; 204 ITR 412 (SC) and distinguished the decision in Rajasthan State Electricity Board v. Associated Stone Industries (2000) AIR 2000 SC 2382 and Aman Marble Industries Private Limited Vs. Collector of Central Excise (20030 157 ELT 393 (SC) and affirmed the decision from Hon'ble Rajasthan High Court in Arihant Tiles & Marbles Private Limited vs. ITO; 295 ITR 148.
Supreme Court of India Cites 6 - Cited by 22 - Full Document

Arihant Tiles And Marbles Pvt. Ltd. vs Income Tax Officer on 30 May, 2007

8. In later decision the Hon'ble Apex Court in Arihant Tiles & Marbles Private Limited (2010) 320 ITR 79 (SC) order dated 2nd December, 2009, Sawing Marble Blocks into slabs and tiles and polishing it was held that it amounts to manufacture or production within the meaning of section 80IA(2)(iii) of the Act. It is pertinent to mention here that while coming to this conclusion, the Hon'ble Apex Court applied the decision pronounced in CIT v. Ses Goa Limited; 271 ITR 331 (SC) and CIT v. N.C. Budhiraja & Company; 204 ITR 412 (SC) and distinguished the decision in Rajasthan State Electricity Board v. Associated Stone Industries (2000) AIR 2000 SC 2382 and Aman Marble Industries Private Limited Vs. Collector of Central Excise (20030 157 ELT 393 (SC) and affirmed the decision from Hon'ble Rajasthan High Court in Arihant Tiles & Marbles Private Limited vs. ITO; 295 ITR 148.
Rajasthan High Court - Jaipur Cites 26 - Cited by 16 - G K Vyas - Full Document
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