Shanti Prime Publication Pvt. Ltd.
Section 10B of Income Tax Act, 1961— Deduction—Test for determination whether manufacture can be said to have taken place is whether the commodity which is subjected to the process of manufacture can no longer be regarded as the original commodity, but is recognized in the trade as a new and distinct commodity. CRGO coils even with a few processes, out of all the processes cannot be used in a transformer unless all the processes were completed and that after completion of all the processes, CRGO/CRNO coils get converted into transformer core which is the end product which can be used in manufacture of transformer and there is no dispute that due to various processes, the end product, which is an input for the purpose of manufacturing transformer, has a distinct name, shape and use and after the raw-material in the form of CRGO/CRNO Coils and/or sheets goes through all the processes, the raw-material looses its identity and a new product comes into existence which is commercially distinct from raw-material on which the processes have been performed, assessee entitled to exemption — PR. CIT vs. Fine Line Circuits Company [2020] 421 ITR 225 (GUJ)