CETA may classify processes as manufacturing for excise duty, but income tax requires genuine manufacturing activity assessment.

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....It is possible that Central Excise Tariff Act (CETA) deems certain processes as manufacturing by placing certain products in a particular chapter for the purpose of excise duty even if they do not fulfil strict criteria of a manufacturing process but for the purpose of Income-tax we have to find out whether the product meets the test of manufacturing activity. - AT....