Court : Income Tax Appellate Tribunal ITAT Nagpur
Decided on : Mar-18-1982
Reported in : (1982)1ITD648(Nag.)
..... processing" was incidentally considered by the learned judges and it was held thus : at some point processing and manufacturing will merge. but where the commodity retains a continuing substantial identity through the processing stage we cannot say that it has been 'manufactured' within the meaning of article 203(6)(6). ..... with a commercial character. he has to operate the x-ray machine and develop the films. although these may be professional activities, they are essentially of a commercial nature.the professional qualifications which the assessee has do not in any way change the character of the commercial activity he is ..... the aac went on to consider the meaning of the word "industry". he held that the word "industry" does not necessarily mean a unit essentially involving in it a factory complex. the then referred to the dictionary meanings of the words "manufacture" and "production". as the assessee converted raw ..... against the order of the aac holding that the assessee was entitled to investment allowance under section 32a(2) of the income-tax act, 1961 ("the act"). according to the ito, the assessee is a medical practitioner doing the job of a "radiologist". it is admitted by the ito ..... to consider whether the assessee is manufacturing or producing articles or things. any fabrication or concoction will necessarily come under "manufacture". production is the act of producing or bringing out. what is brought out is a product. in this sense, the aac is right in holding that when an .....Tag this Judgment!