JOSHI TECHNOLOGIES INTERNATIONAL INC.,,AHMEDABAD vs. THE ASSTT. DIT, (INTL. TAXN.),, AHMEDABAD
In the result appeal of the assessee is allowed
ITA 2389/AHD/2015[2006-07]Status: DisposedITAT Ahmedabad17 Aug 2022AY 2006-07
Bench: Shri Mahavir Prasad & Shri Waseem Ahmedassessment Year : 2003-04 Joshi Technologies International Inc., Asst. Commissioner Of Income- 402, Heritage, Off. Ashram Road, Vs Tax (International Taxation), Usmanpura, Ahmedabad Ahmedabad Pan : Aaacj 9592 P Assessment Year : 2006-07 Joshi Technologies International Inc., Dy. Commissioner Of Income- 701, Parshwanath E Square, Vs Tax (International Taxation-1), Prahladnagar Garden, Near Titanium Ahmedabad Building, Satellite, Ahmedabad Pan : Aaacj 9592 P अपीलाथ"/ (Appellant) "त् यथ"/ (Respondent) Assessee By : Shri S.N. Soparkar, Sr. Advocate With Shri Yogesh G. Shah, Ar Revenue By : Shri Alok Kumar, Cit-Dr & Shri Atul Pandey, Sr Dr सुनवाई क" तार"ख/Date Of Hearing : 02/08/2022 घोषणा क" तार"ख /Date Of Pronouncement: 17/08/2022 आदेश/O R D E R Per Waseem Ahmed, Am : These Are The Appeals Filed By The Assessee Against Two Separate Orders Of The Learned Commissioner Of Income Tax (Appeals), Gandhinagar Dated 12.01.2010 & Learned Commissioner Of Income-Tax (Appeals)-13, Ahmedabad Dated 29.05.2015 Passed For Assessment Years 2003-04 & 2006-07 Respectively.
For Appellant: Shri S.N. Soparkar, Sr. Advocate with Shri Yogesh G. Shah, ARFor Respondent: Shri Alok Kumar, CIT-DR &
Section 143(3)Section 147Section 42Section 42(1)(c)Section 80I
…ITR 331 where the Hon’ble court held as under: 9. The reasoning given by the High Courts, in the decisions noted by us earlier, is, in our opinion, unimpeachable. This Court had, as early as in 1961, in Chrestien Mica Industries Ltd. v. State of Bihar [1961] 12 STC 150 defined the word "production", albeit, in connection which the Bihar Sales Tax Act, 1947. The definition was adopted from the meaning ascribed to the word in the Oxford English Dictionary as meaning "amongst other things that which is produced; a thing that results from any action, process or of fort, a product; a product of human activity or effo…