1985 (5) TMI 28

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....) of the Finance Act, 1968 ? " As it happens, the facts of this case are quite simple. The assessee-company carries on business which can be divided into three classes. It makes ready-made garments, it trades in clothes and it does tailoring for customers. In the year 1971-72, the following figures indicate these business activities : " Assessment year 1971-72 : Sales Gross profits Rs. Rs. (1) Ready-made garments 2,12,601 47,330 (2) Cloth trading accounts 74,509 16,395 (3) Tailoring charges received 2,35,699 52,072 In 1973-74, the following figures are given : " Assessment year 1971-72 : Sales Gross profits Rs. Rs. (1) Ready-made garments 2,52,603 53,300 (2) Cloth trading accounts 92,248 15,603 (3) Tailoring char....

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....ource. It is the admitted case before us, as indicated from the figures set out earlier, that in the case of this company, if the tailoring charges are treated as profits from manufacturing or processing of goods, then the assessee-company qualifies as an industrial company. The learned counsel before us cited a very large number of judgments. We think it is unnecessary to cite all those judgments ; just a few will be sufficient. In CIT v. Ajay Printery Private Ltd. [1965] 58 ITR 811 (Guj), it was held that the business of printing balance-sheets, profit and loss accounts, dividend warrants, etc., was that of manufacturing of goods. On a parity of reasoning, it is urged that the making of clothes from cloth supplied by the customers is a....