COMMISSIONER OF INCOME TAX Vs. SUPRIYA GILL

JUDGEMENT

(1.) THESE appeals are being disposed of by this common judgment since the following identical questions of law are involved in these appeals:

(2.) THE basic question which arises is whether the process of converting limestone into limestone powder is a manufacturing activity within the meaning of Section 80IA and 80IB of the Income Tax Act, 1961.

(3.) IN M/s.Sterling Foods v. State of Karnataka and another, 1986 (3) SCC 469, the question for determination before the Apex Court was whether shrimps, prawns and lobsters subjected to processing like cutting of heads and tails, peeling, deveining, cleaning and freezing cease to be the same commodity or become a different commodity. The Apex Court held as follows: -