1978 (11) TMI 103

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.... pickles masalas and various types of spices. The assessee claimed an exemption under s. 5(1)(xxxii) of the WT Act the value of the interest in the assets forming part of the business carried on by the partnership firm Ms. D.R. Chillal & Sons. The Wealth tax Officer held that the claim is not admissible and the assessee has invested in a firm which cannot be termed as an industrial company. He was....

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....e order of the AAC. 3. The meaning of the expression "manufacturing and processing of goods" came up for consideration before the Bench of the Tribunal to which one of us, the Accountant Member, was a party in ITA No. 917/PN/76-77. The Tribunal referred to the decision of the Supreme Court in AIR 1963 page 791 wherein the Supreme Court defined the term "manufacture" to mean as follows: "Manu....

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....or in the construction of ships or in the manufacture or processing of goods or in mining. The instant case falls within the expression "manufacturing of goods". The firm in which the assessee is a partner manufactures Pickles and Spices. The product manufactured by the firm is something which is entirely different from the raw materials used and thus the manufacturing activities result into bring....