To decide if Assessee has manufactured a product or merely assembled, AO should have taken expert opinion

HIGH COURT OF MADHYA PRADESH Aartech Solonics Ltd. versus Commissioner of Income-tax KRISHN KUMAR LAHOTI AND Smt. Vimla Jain, JJ IT Appeal No. 202 of 2010 DECEMBER  4, 2012 ORDER 1. This writ appeal was admitted on 1.12.2010 on the following substantial question of law:- “Whether, the Tribunal, in arriving at a conclusion that the assessee has not assembled any product at all, exceeded its jurisdiction and scope of the proceedings before it by coming to a different factual finding totaling beyond the issue arising out of the first appellate order?” 2. Facts of th...