2019 (10) TMI 83

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.... For Appellant: Mr. K. Ravi For Respondent: Mr. T.R. Senthil Kumar, (In all Appeals) Senior Standing Counsel assisted by Ms. K.G. Usharani, Junior Standing Counsel COMMON JUDGMENT (Delivered by T.S. Sivagnanam, J.) These appeals by the appellant/assessee filed under Section 260A of the Income-tax Act, 1961 are directed against the order dated 04.02.2013, passed by the Income Tax App....

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....stion law framed for consideration was considered by a Division Bench of this Court and was decided in favour of the assessee in the assessee's own case in T.C.(A) Nos.341 and 342 of 2007, dated 21.06.2018 [M/s.DXN Herbal Manufacturing (India) Pvt. Ltd., vs. The Income Tax Officer, Ward-I(1), Puducherry] to which, one of us (TSSJ) was a party. The operative portion of the judgment read as foll....

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....mounts to production of a new article and whether the assessee was entitled to relief under Sections 80J and 80HH of the Act. 24. This Court held that the common thread which runs in all the decisions is that only when a new distinct commodity commercially accepted as such, comes into existence as a result of processing, that a commodity can be said to have been manufactured and in the sa....