COMMISSIONER OF INCOME TAX Vs. VINBROS & COMPANY

JUDGEMENT

(1.) This appeal is filed by the Revenue seeking admission by framing the following question of law:

(2.) In the proceedings before the Commissioner of Income-tax (Appeals), the Assessee explained the process of blending as follows:

(3.) The Commissioner of Income-tax (Appeals) considered the fact that the alcoholic strength of ENA which was around 95 per cent, v/v was reduced to a maximum of 42.8 per cent. v/v. Consequently, the Commissioner of Income-tax (Appeals) held that there was no manufacture or production of any new article or thing as the alcohol which was the input remained as alcohol. In the circumstances, he rejected the plea for deduction under Section 80-IB of the Act.