1980 (10) TMI 103

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....78-79 asst. yr. 1976-77—Departmental appeal: The assessee had debited to profit and loss account purchase tax of Rs. 3,47,892. The purchases of the assessee for this year amounted to about Rs. 65 lakhs. What it sold this year was only Rs. 62 lakhs. The ITO was of the view that the assessee need pay purchase tax only for purchases which have been sold during the year. So the purchase tax for Rs. ....

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....sed is as follows: "The AAC went wrong in his finding that the business of the assessee is eligible for the deduction under s. 80HH. He ought to have held that processing of Sea Foods do not amount to manufacture or production of articles. He also ought to have held that in any case the assessee having got done the major portion of the operations of processing by another concern, it is not enti....

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....ing. 6. Such processing for purposes of IT Act amounts to production is clear from s. 33 of IT Act, 1961. If processed (including frozen) fish and fish products is the end product of a business it is treated as manufacture or production for purposes of s. 33. So this processing is considered as a processing for production. See such type of interpretation made in Tarai Development Corporation vs....