1984 (1) TMI 12

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....hing, dyeing and centering the same. Considering the nature of the operations carried on the cloth purchased by the assessee, the ITO was of the view that these operations did not amount to " manufacture or production of textiles ". The assessee's claim for development rebate at the special rate of 35% was thus negatived. Aggrieved by this, the assessee preferred an appeal and the AAC found that though no " textiles " as such were either " manufactured or produced ", the operations carried on by the assessee had the only effect of making the material more presentable and neater and, in that view, the assessee was held not entitled to claim higher development rebate at 35%. On further appeal by the assessee to the Tribunal, the Tribunal reli....

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....see did not manufacture the cloth but merely expended its labour on the cloth manufactured by others by bleaching, dyeing, centering and printing the cloth. The basic quality of the commodity as cloth had remained the same both at the time of its purchase by the assessee and even after the carrying on by the assessee of the operations referred to above. The assessee started with cloth purchased from outside and ended up with cloth even after performance of the operations. In other words, the end product in this case is not any different from the feed-in-material. It is the manufacture or production or bringing into existence of textile material or cloth or fabric that is contemplated under s. 33(1)(b)(B)(i) of the I.T. Act, 1961, read with ....