2004 (12) TMI 66

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....palle J. - This appeal arises from the order dated September 28, 2001, passed by the Income-tax Appellate Tribunal, Panaji, by allowing an appeal against the order passed by the Assistant Commissioner of Income-tax as an Assessing Officer. The question of law as raised in this appeal is: "Whether the operations carried out by the assessee namely of lamination, punching and pasting with glue for th....

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....l filed by the assessee has been allowed in terms of the impugned order. The Assessing Officer noted that the following operations as part of the process of making cartons were carried out in the premises of the assessee: (a) The printed sheets are brought to the factory of the assessee-company and laminated to make the surface of the sheets smooth and attractive; (b) The laminated sheets are p....

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.... treatment, labour and manipulation. But something more is necessary and there must be transformation; a new and different article must emerge having a distinct name, character or use. Thus the activities undertaken by the assessee-company with the use of machinery does produce some change in the paper used as a raw material but does not bring into existence a new substance which is required to ca....

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....for manufacture of printed laminated carton is a paperboard corrugative sheets, which have different uses. The final product is printed product is printed paperboard container, plain and varnished laminated, foil embossed and waxed cartons, printed E-flute corrugated board cartons and printed catch covers. The characteristics of the finished goods are totally changed after laminating, corrugating,....