Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Process amounting to manufacture - The appellant's contention was that the activities—testing, labeling, and packing—performed on imported modems did not amount to manufacture, as the modems were already in a marketable state upon import. They argued that these processes were essential quality checks and did not alter the modem's identity, thus not constituting manufacture. - The Tribunal held that testing, labeling, and packing of modems, coupled with the inclusion of additional accessories, amounted to making the product marketable to the consumer, thereby falling within the definition of manufacture.
Process amounting to manufacture - The appellant's contention was that the activities—testing, labeling, and packing—performed on imported modems did not amount to manufacture, as the modems were already in a marketable state upon import. They argued that these processes were essential quality checks and did not alter the modem's identity, thus not constituting manufacture. - The Tribunal held that testing, labeling, and packing of modems, coupled with the inclusion of additional accessories, amounted to making the product marketable to the consumer, thereby falling within the definition of manufacture.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
