COMMISSIONER OF INCOME TAX Vs. ASSOCIATED MINERALS INDUSTRIES

JUDGEMENT

(1.) Both the appeals are being disposed of by this common judgment since the following identical questions of law are involved in both the 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 Black's Law Dictionary (5th Edition), the work "manufacture" has been defined as, "the process or operation of making goods or any material produced by hand, by machinery or by other agency; by the hand, by machinery, or by Article The production of articles for use from raw or prepared materials by giving such materials new forms, qualities, properties or combinations, whether by hand labour or machine".