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Mineral extraction from beach sand is manufacturing; eligible for Section 32AC tax deduction, not denied by Section 263.

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....Eligibility to claim deduction u/s 32AC - the extraction of minerals from beach sand involve change in non-living physical object / article into a new and distinct object / article having different name and use. Thus, the same would amount to manufacture. - Benefit of deduction cannot be denied, moreover by invoking revision proceedings u/s 263 - AT....