Supreme Court of India
M/s. Chillies Exports House Ltd. v. Commissioner of Income Tax
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What the Court ordered
We are of the view that the decision in the three instant appeals solely based on the earlier decision of the High Court of Madras, rendered in 115 ITR 73, when such materials were not available, cannot stand.
Judgment, page 12
From the headnote
Finance Acts of 74-75, 76-77 & 77-7/r-S. 2(8)(c) of 74, S. 2(7)(c) of 76 and S. 2(6)( c) of 77, respectively-The tenn 'processing of goods' in relation to an 'llldustrial Company'-Ref ers to the c11111u/ative effect of all the activities canied out to make the goods marketable/aportable, and it is immatelial even if some part of that activity is done by an outside agency. c The short question raised in these Appeals was whether the Appel· !ant was entitled to the concessional tax as applicable under S. 2(8)(c) of the Finance Act 74-75 based on a finding of whether there was 'processing of
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