Processing of printed sheets into journals qualifies as industrial activity for concessional tax treatment.

Folding and stitching printed sheets into usable journal parts amounted to processing of goods, even though the assessee did not itself print the journal and the printing was done by another concern. The assessee's role was limited to receiving the printed sheets, arranging folding and stitching through labour contractors, then packing and despatching the completed journal to subscribers. On that basis, the activity fell within the statutory expression "manufacture or processing of goods", and the company was treated as an industrial company entitled to the concessional tax rate under the Finance Act, 1968.

---

---

Issues: Whether the assessee-company was carrying on the business of manufacturing or processing goods so as to qualify as an industrial company entitled to the concessional rate of tax under the Finance Act, 1968.

Analysis: The assessee did not itself print the journal, that work having been done by another concern. Its activities consisted of receiving the printed sheets, folding and stitching them through labour contractors, and then packing and despatching the completed journal to subscribers. The expression used in the statutory definition was "manufacture or processing of goods". Even though the assessee was not engaged in manufacture, the folding and stitching of printed sheets into usable parts or books amounted to processing of goods within the statutory meaning.

Conclusion: The assessee-company was engaged in processing of goods and was therefore an industrial company entitled to the rate of tax applicable under Paragraph F of Part I of the First Schedule to the Finance Act, 1968.

---