2008 (1) TMI 936

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....GMENT The appellant has framed three questions of law. However, for deciding this appeal the relevant question of law is (b) and the same is reproduced as under : "(b) Whether on the facts and circumstances of the case and in law, the Hon'ble Tribunal was justified in holding that the assessee's activity can be considered as manufacturing activity since the assessee is only cru....

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....ourt in the case of CIT vs. Sesa Goa Ltd. (2004) 188 CTR (Bom) 120: (2004) 266 ITR 126(Bom) as affirmed by the Supreme Court in the case CIT vs. Sesa Goa Ltd. (2004) 192 CTR (SC) 577: (2004) 271 ITR 331(SC) and confirmed the finding of the CIT(A). 4. In our opinion, considering that the expression "production" is of much wider amplitude than the expression manufacture and the finding of fact re....