Conversion of marble blocks into polished slabs and tiles constitutes ‘manufacture’ or ‘production’ u/s 80-IA

The assessee was engaged in conversion of marble blocks into slabs and tiles by sawing and polishing. The question was whether this amounts to “manufacture or production of article or thing” for purposes of deduction u/s 80IA. HELD, deciding in favor of the assessee: (i) The word “production” is wider in its scope than the word “manufacture”. It means manufacture plus something in addition thereto. This ground reality is now noted in s. 2(29BA) inserted by Finance Act, 2009 w.e.f 1.4.2009. In Lucky Minmat 245 ITR 830 (SC), it was held that mere mining of limestone and marble and cu...