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1 - 7 of 7 (1.34 seconds)Commissioner Of Income-Tax, Bombay ... vs Tata Locomotive & Engineering Co., Ltd on 13 January, 1966
In the case of CIT v. Tata Locomotive and Engineering Co. Ltd. [1968] 68 ITR 325, the Division Bench of the Bombay High Court had to consider this question and observed that the word "manufacture" had a wider and also a narrower connotation. In the wider sense, it simply meant making or fabricating or bringing into existence an article or product either by physical labour or by power and the word "manufacture" in the ordinary parlance would mean a person who made, fabricated or brought into existence a product or an article by physical labour or power. The other shade of meaning which, according to the Division Bench of the Bombay High Court, was the narrower meaning, implied transforming raw materials into a commercial commodity or a finished product which had an entity by itself but it did not necessarily mean that the materials with which the commodity was so manufactured must lose their identity. But both the words "manufacture" and "produce" applied to bringing into existence something which was different from its components. Whether one took into account the wider or narrower meaning of the word manufacture, according to the Division Bench of the Bombay High Court, was assembling of automative bus or truck chassis from imported parts in a knocked down condition would give rise to an article which was totally different from the parts and would amount to manufacture. Applying that test the question before us would be whether the process of galvanizing brought into existence an article known commonly as different before galvanisation. We have noted the dictionary meaning of the word "galvanizing". Galvanisation is an act or process of galvanising or coating to protect it from rust. This does not bring into existence a different article or an article commonly known to the people differently who deal with it before it was galvanised.
Commissioner Of Income-Tax vs Radha Nagar Cold Storage (P.) Ltd. on 4 June, 1980
This work of galvanisation may or may not be processing, We had noted in the case of CIT v. Radha Nagar Cold Storage (P.) Ltd. that the expression "process" was different from the expression "manufacturing". In this section, what is required is that the articles should be manufactured or produced. The process of galvanising does not result in the manufacture or production of new goods as such. In that view of the matter, we are of the opinion that the assessee-company does not fulfil Clause (iii) of Sub-section (2) of Section 84 of the I.T, Act, 1961, as it stood at the relevant time. In the aforesaid view of the matter, the question is answered in the affirmative and in favour of the revenue.
Commissioner Of Income-Tax, Gujarat vs Ajay Printery Private Ltd. on 17 September, 1965
In the case of CIT v. Ajay Printery P. Ltd. [1965] 58 ITR 811, the Division Bench of the Gujarat High Court was concerned with the business of printing balance-sheets, profit and loss accounts, dividend warrants, pamphlets, share certificates, etc. It was held by the Division Bench of the Gujarat High Court that the business of printing balance-sheets, profit and loss accounts, dividend warrants, pamphlets, share certificates, etc., required by companies was a business which consisted wholly of "manufacture of goods" within the meaning of Clause (ii) of Expln. 2 to Section 23A of the Indian I.T. Act of 1922. The pamphlet or the balance-sheet or the share certificate, according to the Division Bench of the Gujarat High Court, if we may say so with respect rightly, is an -article quite different from the raw materials, paper and ink from which it is made, the user of which would be different from the user of the raw materials used in producing it. In those circumstances, the Gujarat High Court came to the conclusion that production or bringing those articles into existence is manufacture or production of that article.
Section 256 in The Income Tax Act, 1961 [Entire Act]
The Income Tax Act, 1961
Section 33B in The Income Tax Act, 1961 [Entire Act]
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