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The appeal addressed the scope of the terms "manufacture" and "production" u/s 80IA of the Income-tax Act. The court held that the conversion of blocks into polished slabs and tiles constituted manufacture, creating a new distinct commodity. This activity went beyond mere manufacturing, resulting in the emergence of a new product. Denying such activity as manufacturing u/s 80-IA would have dire consequences for the assessees, impacting their tax liabilities. The High Court's decision in favor of the respondents was upheld, granting them the benefit of section 80-IA.
The appeal addressed the scope of the terms "manufacture" and "production" u/s 80IA of the Income-tax Act. The court held that the conversion of blocks into polished slabs and tiles constituted manufacture, creating a new distinct commodity. This activity went beyond mere manufacturing, resulting in the emergence of a new product. Denying such activity as manufacturing u/s 80-IA would have dire consequences for the assessees, impacting their tax liabilities. The High Court's decision in favor of the respondents was upheld, granting them the benefit of section 80-IA.
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