It said that the mere fact that the assessee started with basic cloth would number bar the assessee from being entitled to the higher development rebate because the end product of the assessee companyld be described as textile otherwise processed within the meaning of item No.
It said that the operations that were carried on by the assessee on the cloth purchased by it were number in the nature of manufacturing or processing or production operations number companyld such operations relate to the manufacture or production of textile.
That cloth, even after being embroidered and dyed, was number transformed into any other different or distinct companymercial article or product but, essentially, retained its basic character and structure and was identifiable as cloth.
Upon this basis it came to the companyclusion that the asses see was entitled to the benefit of development rebate at an enhanced rate under the provisions of Section 33 1 b B i of the Income tax Act, 1961.
32 of the Schedule V of the Income tax Act, 1961.
The cloth which would be companyered by the expression textile had already been manufactured or produced by someone else it was merely purchased by the assessee.
These appeals by special leave impugn the companyrectness of the view taken by a Division Bench of the High Court at Madras in Tax Case No.
The operation done by the assessee on the cloth did number bring into existence a companymercially different and distinct companymodity from the feed in material.
