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Commissioner Of Income-Tax, Gujarat vs Ajay Printery Private Ltd. on 17 September, 1965

The Gujarat High Court's judgment in the case of CIT v. Ajay Printery (P.) Ltd. [1966] 58 ITR 811, which was pronounced in the context of Clause (ii) of Explanation 2 to Section 23A of the 1922 Act [section 109(iii) of the 1961 Act], applies equally in the matter of charging tax at a lower rate which is applicable in the case of companies having business in the 'manufacturing or processing of goods'. In view of this decision, printing presses are entitled to the aforesaid lower rate of tax and the benefit will be available from the asst. year 1964-65 onwards. The assessments already completed may, accordingly, be rectified under Section 154 apply the lower rate of tax and refunds, if due, may be granted. The Board are also of the view that the ratio of the Gujarat High Court's judgment in the case of Ajay Printery (P.)
Gujarat High Court Cites 16 - Cited by 67 - J M Shelat - Full Document

Commissioner Of Income-Tax vs Commercial Laws Of India Pvt. Ltd. on 8 December, 1976

The Board has received representation that companies engaged in publishing of books should be treated as industrial companies for the purpose of Section 104 of the IT Act, 1961. Reference has been made in this connection to the decisions of the Madras and Calcutta High Courts in the cases of CIT v. Commercial Laws of India (P.) Ltd. [1977] 107 ITR, 822 and Addl.
Madras High Court Cites 5 - Cited by 26 - Full Document

Addl. Commissioner Of Income-Tax vs A. Mukherjee And Co. (P.) Ltd. on 1 September, 1977

CIT v. A. Mukherjee & Co: (P.) Ltd. [1978] 113ITR 718, respectively. In the Madras decision it has been held that folding and stitching the printed sheets and converting them into parts or books, as the case may be, constitute processing of goods. In the Calcutta decision it was held that it is wholly unnecessary for a publisher of books to be an owner of a printing press or to be himself a book binder to be a manufacturer of books. A publisher may get the books printed from any printer, but the printer is a mere contractor and the publisher carries on the business of manufacturing and processing of goods.
Calcutta High Court Cites 6 - Cited by 68 - Full Document

Orient Longman Ltd. vs Commissioner Of Income-Tax, Delhi-Ii on 28 March, 1980

19. We are also of the view that the case law referred to by the learned Counsel during the course of the hearing supports the assessee's case. The authorities cited before us were also relied upon in the course of the first appellate proceedings and have been duly considered by the CIT(A). For purposes of disposing of the present appeals we need refer to only two of these authorities since these have subsequently been accepted by the Board as well as suitable instructions issued to the assessing officers to follow them. The first decision would be that of the Hon'ble Gujarat High Court in the case of Ajay Printery (P.) Ltd. (supra). The issue before the Hon'ble High Court was whether the printing of balance sheets and dividend warrants amounted to "manufacture of goods". The High Court was of the view that the end-product, namely, the balance sheet or the share certificate was an article quite different from the raw materials such as paper and ink from which it was made. It was held that the aforesaid activity amounted to "manufacture of goods". The CBDT vide Circular P. No. 91/60/66-ITJ, dated 9-5-1967 issued the following instructions :
Delhi High Court Cites 4 - Cited by 29 - Full Document
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