1978 (2) TMI 2

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.... J. -The question referred for our opinion reads as follows : "Whether the profit of Rs. 3,73,870 obtained by the assessee during the relevant previous year by the sale of chemicals imported by it on the strength of licences issued to it, based on its export performance of leather, both manufactured and purchased by it, was rightly held as not attributable to the manufacturing activity carried ....

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....to any of the aforesaid activities included in its gross total income for the relevant previous year is not less than fifty-one per cent. of such total income." The assessee is engaged in the manufacture of leather. The assessee also purchases leather. Both the manufactured leather and the purchased leather are exported As a result of such export, the assessee has been granted import entitlemen....

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....cture or processing of goods ... if the income attributable to (the same) included in its gross total income for the relevant previous year is not less than fifty-one per cent. of such total income." The question is whether the business consists mainly of the manufacture of goods as in sub-section (4)(a) of section 104 as has been explained by the statutory explanation. "Attributable" is not a ....