2012 (4) TMI 757

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....karan, The appeal of the Revenue is directed against the Order dated 02-12-2009 passed by the Ld. CIT(A)-IV, Kochi and it relates to the assessment year 2006-07. 2. The solitary issued urged in this appeal is whether the activities carried out by the assessee can be termed as manufacture or production of an article or thing in the context of allowing additional depreciation u/s. 32(1)(iia) of ....

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.... to term the activities of the assessee as manufacture or production. Accordingly, he disallowed the additional depreciation claimed by the assessee. The order of the Assessing Officer was challenged before the Ld. CIT(A) and the first appellate authority allowed the claim of the assessee. Aggrieved by the order of the Ld, CIT(A), the Revenue is in appeal before us. 4. The Ld. DR submitted that ....

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....s, they become fit for human consumption. Accordingly, he submitted that the activity carried on by the assessee results in a commercially distinct product and hence such activities fall in the category of manufacture or production of an article or thing. 5. We have heard the rival contentions and carefully perused the record. We notice that the Hon'ble Supreme Court of India had an occasion to ....

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.... been held that processed or frozen shrimps and prawns are commercially regarded as the same 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 p....