COMMISSIONER OF INCOME TAX Vs. TARA AGENCIES

JUDGEMENT

(1.) THIS tax revision case at the instance of the Commissioner of Income-tax arises out of the order passed by the Income-tax Appellate Tribunal, Cochin Bench, in I. T. A. No. 587/Cochin of 1988. The relevant assessment year is 1979-80. The following questions are referred for the opinion of this court :

(2.) THE relevant facts are as follows :

(3.) THE Department took the view that when different varieties of tea purchased by the assessee were blended together, it undergoes a process and the goods are altered after purchase. THE court observed that the expression "process" has not been defined in the Act. THE meaning of the word "process" given in Webster's Dictionary was quoted as follows :