Shri Puneet Sehdev Vs ITO (ITAT Amritsar)
The activity for converting gold bricks, biscuits or bars, into jewellery amounts to ‘production or manufacture of a new article. The gold, silver or platinum in bar, biscuits or brick form, is converted by manual labour and by the use of implements/tools or by machinery, culminating into an entirely new article/thing called jewellery or ornaments. Jewellery is a wearable item and is used by both men and women.
Jewellery/ornaments in common parlance or in commercial terms has a distinct identity, treated as a new article and not the same as raw or standard gold in the form of bricks, biscuits or bars. As a result of the said processing a commercially different saleable product comes into existence. Jewellery has a distinctive name, character and use. It can no longer be regarded as the original commodity, has separate consumers and is a new commercial commodity. The activity of the respondent assessee amounts to ‘manufacture or production and, therefore, qualifies for deduction under section 80IB.
FULL TEXT OF THE ORDER OF ITAT AMRITSAR
The captioned appeals are directed against the respective orders of the CIT(A), Jammu, as under :
| ITA
No./appellant |
Assessment Year | Details of impugned order | Details of assessment /penalty order |
| ITA 305/Asr/2015 (Assessee) | A.Y 2008-09 | CIT(Appeals),Jammu– Order dated 30/03/2015 | Assessment order u/s. 143(3)
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