https://www.taxtmi.com/caselaws?id=5592 SC held that the characterisation of the assessee as an "industrial company" under the relevant Finance Acts could not be concluded solely on the basis of earlier HC precedent, which had ignored a material activity, namely fumigation with methyl bromide carried out under contract by a third party. SC ruled that the determinative issue is whether, considering the cumulative effect of sorting, grading, clipping, stemming and fumigation, the assessee is engaged in "processing of goods." Since the HC failed to undertake a comprehensive factual and legal analysis in this perspective, SC set aside the impugned judgments and remanded the matter to the HC for de novo consideration. Appeals allowed. en-us Tue, 22 Apr 1997 00:00:00 +0530 Tue, 16 Dec 2025 13:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5592 SC held that the characterisation of the assessee as an "industrial company" under the relevant Finance Acts could not be concluded solely on the basis of earlier HC precedent, which had ignored a material activity, namely fumigation with methyl bromide carried out under contract by a third party. SC ruled that the determinative issue is whether, considering the cumulative effect of sorting, grading, clipping, stemming and fumigation, the assessee is engaged in "processing of goods." Since the HC failed to undertake a comprehensive factual and legal analysis in this perspective, SC set aside the impugned judgments and remanded the matter to the HC for de novo consideration. Appeals allowed. Case-Laws Income Tax Tue, 22 Apr 1997 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5592