Industrial company status upheld where production work amounted to processing and no referable question of law arose.

Production of design and art works, print material, software for audio visuals, commercial spots, jingles and publicity texts was treated as processing, so the assessee qualified as an industrial company entitled to the concessional rate of tax. The SC also held that the Tribunal's conclusion was correct on the material before it, and that no referable question of law arose from the finding. The Revenue's request for a reference therefore failed.

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Issues: Whether the assessee was rightly treated as an industrial company entitled to concessional rate of tax and whether any referable question of law arose from the Tribunal's conclusion.

Analysis: The Tribunal recorded the assessee's activities, which included production of design and art works, print material, software for audio visuals, commercial spots and jingles, and publicity texts. On that basis, it held that the activities amounted to processing and that the assessee qualified as an industrial company. The Court found that the Tribunal's conclusion was correct and that the refusal to refer the question was justified because no referable question of law arose.

Conclusion: The assessee was held to be an industrial company entitled to the concessional rate of tax, and the Revenue's reference request failed.

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