ASSSISTANT COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1 1, CHENNAI vs. INDIAN GARNET SAND COMPANY PVT LTD, CHENNAI

ITA 3833/CHNY/2025Status: DisposedITAT Chennai05 May 2026AY 2009-109 pages
AI SummaryDismissed

What were the facts?

The assessee, a 100% EOU, claimed exemption under Section 10B for processing raw sand into garnet sand for export. The Assessing Officer disallowed this exemption, stating the activity was not 'manufacture'. The CIT(A) allowed the exemption, a decision the Revenue appealed.

What did the Tribunal hold?

The Tribunal held that the extraction and processing of garnet from beach sand constitutes 'manufacture' as defined under the Act. Consequently, the assessee is eligible for the deduction under Section 10B.

What were the issues?

Whether the activity of extracting and processing garnet sand from natural sand amounts to 'manufacture' for the purpose of Section 10B exemption.

Which sections of the Income-tax Act were involved?

Section 10B,Section 2(29BA)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘D’ BENCH: CHENNAI

Before: SHRI ABY T. VARKEY & MS. PADMAVATHY.S

Hearing: 29.04.2026Pronounced: 05.05.2026

PER PADMAVATHY.S

The order continues below.

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