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The term manufacture occurring in Sections 80-IB(2) and (5) as also 80-IE, necessarily requires that the end product of the manufacturing process is to be completely different from ingredients, as regards its chemical composition, integrant structure or its use.

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Sec. 80-IB of Income Tax Act, 1961 - Deduction – Revenue filed Tax Appeal against the order of Tribunal. By the impugned order, the Tribunal was pleased to uphold the decision of the CIT (A) and dismiss the appeals of the Revenue. The Tribunal held that the activity of making poultry feed, as carried on by the Assessee, was not a mere process of mixing, but that of manufacture. It was held that the Assessee was itself carrying on the complete activity, id est, from mixing, grinding till pollicisation of all the ingredients and that the raw materials once consumed thus, could not be reconverted into the same position, and that its utility got changed. Thus, Tribunal held that the action of the AO of disallowing the deduction claimed by the Assessee under Section 80-IB (5) was not justified. High Court agreeing the finding of Tribunal dismissed the Tax Appeal of the revenue. - PR. CIT V/s SONA VETS PVT. LTD. - [2020] 424 ITR 387 (CAL)

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