1999 (3) TMI 9

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.... concerned in this appeal by the Revenue, relating to the assessment year 1977-78 reads thus (see [1989] 180 ITR 454, 455) : "Whether, on the facts and in the circumstances of the case, (i) the assessee's business involves 'production' ? (ii) the assessee is entitled to exemption under section 80HH of the Income-tax Act, 1961 ?" The assessee claimed the allowance under section 80HH of ....

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....find from the judgment of the Kerala High Court in the case of Mar well Sea Foods' case [1987] 166 ITR 624, that Marwell Sea Foods had placed before the taxing authorities a detailed description of the process by which prawns were prepared for export and, that the appellate authorities had understood the various stages through which the prawns passed as processes involving production or manufactur....

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....me commodity as raw shrimps and prawns. When raw shrimps and prawns are subjected to the process of cutting of heads and tails, peeling, deveining, cleaning and freezing they do not cease to be shrimps and prawns and become other distinct commodities. There is no essential difference between raw shrimps and prawns and processed or frozen shrimps and prawns. In common parlance they remain known as ....