https://www.taxtmi.com/caselaws?id=9649 Blending different grades and varieties of tea purchased by a trader does not amount to manufacture or production of an article or thing for deduction under section 80-IB(2)(iii). The controlling test is whether the activity brings into existence a new and commercially distinct commodity; mere processing that improves quality, flavour, or marketability is insufficient. On that principle, blended tea remains tea and no new product emerges. The wider meaning of "produce" does not extend to such marketing-oriented processing, and the activity also does not fit agricultural income principles because the trader is not the grower. en-us Mon, 18 Jul 2005 00:00:00 +0530 Wed, 06 Jul 2016 15:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=9649 Blending different grades and varieties of tea purchased by a trader does not amount to manufacture or production of an article or thing for deduction under section 80-IB(2)(iii). The controlling test is whether the activity brings into existence a new and commercially distinct commodity; mere processing that improves quality, flavour, or marketability is insufficient. On that principle, blended tea remains tea and no new product emerges. The wider meaning of "produce" does not extend to such marketing-oriented processing, and the activity also does not fit agricultural income principles because the trader is not the grower. Case-Laws Income Tax Mon, 18 Jul 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=9649