Would the procurements of parts and assembling them to make windmill fall within the meaning of “manufacture” and “production” to be entitled for deduction under section 80-IB?

CIT Vs. Chiranjjeevi Wind Energy Ltd. (2011) 333 ITR 192 (Madras High Court) The Supreme Court, in India Cine Agencies v. CIT(2009) 308 ITR 98, laid down that the test to determine whether a particular activity amounts to “manufacture” or not is whether new and different goods emerge having distinctive name, use and character. Further, the Supreme Court, in CIT v. Sesa Goa Ltd. (2004) 271 ITR 331, observed that the word “production” or “produce” when used in comparison with the word “manufacture” means bringing into existence new goods by a proce...