TaxTMI Login
AI OCR ✕Convert scanned orders, printed notices, PDFs and images into clean, searchable, editable text within seconds. Starting at 2 Credits/page
Try Now →Just a moment...
AI OCR ✕Convert scanned orders, printed notices, PDFs and images into clean, searchable, editable text within seconds. Starting at 2 Credits/page
Try Now →
Press 'Enter' to add multiple search terms. Rules for Better Search
Use comma for multiple locations.
---------------- For section wise search only -----------------
Accuracy Level ~ 90%
of 
Press 'Enter' after typing page number.
of Press 'Enter' after typing page number.
No Folders have been created
Are you sure you want to delete "My most important" ?
NOTE:
of Press 'Enter' after typing page number.
of Press 'Enter' after typing page number.
All Case Laws
of Press 'Enter' after typing page number.
of Press 'Enter' after typing page number.
All Case Laws
Note
Bookmark
Share
Don't have an account? Register Here
of Press 'Enter' after typing page number.
Issues: Whether assembling bus or truck chassis from completely knocked down imported packs amounted to manufacture or production of articles within section 15C(2)(ii) of the Income-tax Act, 1922, so as to mark the commencement of the exemption period under section 15C(6).
Analysis: The words "manufacture" and "produce" were held to bear both a wide and a narrower meaning, and on either view the assembly of numerous imported components into a complete self-propelled chassis resulted in a commercially distinct finished article. The activity was not treated as a separate experimental venture divorced from the undertaking; it formed part of one integrated industrial programme approved by the Government of India for the manufacture of diesel trucks. The Court also declined to restrict the statutory language by reference to a supposed legislative intention where the words themselves were plain, and held that the initial assembly stage fell within the industrial undertaking for the purposes of section 15C.
Conclusion: The assembling activity amounted to manufacture or production of articles, and the statutory exemption period commenced in the relevant previous year; the answer was against the assessee and in favour of the Revenue.
TaxTMI 
TaxTMI 
