Printing activity treated as manufacture, so the company qualified as an industrial company for concessional tax treatment.

A company mainly engaged in printing was treated as an industrial company because printing was regarded as manufacture or processing of goods. The reasoning drew support from allied legislation, including the Factories Act, where printing forms part of a manufacturing process, and from the company's factory registration and coverage under the Employees State Insurance Act, which reinforced its manufacturing character. The printed product was also viewed as different from the raw materials used. References to Income-tax Act schedules were held irrelevant to the concessional treatment claimed under the Finance Acts, and the company was entitled to the concessional rate of tax.

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Issues: Whether a company engaged in printing works is an industrial company entitled to the concessional rate of tax under the relevant Finance Acts, and whether printing activity amounts to manufacture or processing of goods.

Analysis: The definition of industrial company in the relevant Finance Acts covered a company mainly engaged in the manufacture or processing of goods. The expression was construed in the light of allied legislation, particularly the Factories Act, 1948, where printing is included within manufacturing process. The company was registered as a factory and was governed by the Employees State Insurance Act, which supported the conclusion that its activity fell within manufacturing. Printing was also treated as manufacture on the footing that the printed product is different from the raw materials used. The references to schedules under the Income-tax Act were held to be irrelevant to the concession claimed under the Finance Acts.

Conclusion: The assessee was held to be an industrial company and was entitled to the concessional rate of tax.

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