Conversion of jumbo rolls of photographic films into small rolls of various sizes is manufacture or not?

IN THE SUPREME COURT OF INDIA CIVIL APPELLATE JURISDICTION CIVIL APPEAL NOS. 3649-3650 OF 2003 M/s India Cine Agencies Versus Commissioner of Income Tax, Madras Civil Appeal No. 1522 of 2007 Civil appeal No. 3720 of 2007 Civil appeal Nos. 451-452 of 2008 Civil appeal Nos. 6835-6836 of 2005 JUDGMENT Dr. ARIJIT PASAYAT, J. 1. In all these appeals common questions are involved relating to the entitlement of benefit in terms of Section 32AB, Section 80HH and Section 80I of the Income Tax Act, 1961 (in short the `Act’). In all these cases the issue is the effect of conversio...