CIT v. Neo Pharma (P.) Ltd.

137 ITR 879High Court1982#6056 most cited
19

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2014 to 2022.

Judgments citing CIT v. Neo Pharma (P.) Ltd.

N CORE CABLES,,DAMAN vs. THE ACIT, VAPI CIRCLE,, VAPI

In the result, the appeal of the Assessee for AY 2005-06 is partly allowed for statistical purposes

ITA 689/SRT/2018[2007-08]Status: DisposedITAT Surat19 Dec 2022AY 2007-08

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.323 To 327/Srt/2018 Ays: (2005-06 To 2007-08, 2009-10 & 2011-12) (Virtual Court Hearing) N. Core Cables, Vs. The Acit, Vapi Circle, Gala No.7, Plot No.10, Primier Vapi. Industrial Area, Kachigam, Daman-396210, U.T Of Daman & Diu. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaefn7954N (Appellant) (Respondent) आयकर अपील सं./Ita No.689/Srt/2018 Assessment Year: (2007-08) (Virtual Court Hearing) N. Core Cables, Vs. The Acit, Vapi Circle, Gala No.7, Plot No.10, Primier Vapi. Industrial Area, Kachigam, Daman-396210, U.T Of Daman & Diu. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaefn7954N (Appellant) (Respondent) Assessee By Shri A. Gopalkrishnan, Ca Respondent By Shri Vinod Kumar, Sr. Dr 10/10/2022 Date Of Hearing Date Of Pronouncement 19/12/2022

Section 143(3)Section 80I

…party premises using their machinery under the supervision and control of an assessee amounts to manufacturing by the industrial undertaking. While holding as such the honorable court followed its own decision in the case of CIT v. Neo Pharma (P.) Ltd. [1982] 137 ITR 879 and Calcutta High Court in the case of Addl. CIT v. A. Mukherjee & Co. (P.) Ltd. [1978] 113 ITR 718. The relevant findings of the Hon`ble Court is reproduced below: “3. In our judgment, the answer to this question is squarely covered by the judgment of our High Court in the case of CIT v. Neo Pharma (P.) Ltd.[1982] 137 ITR 879. In this case, it w…

N CORE CABLES,DAMAN vs. THE ACIT,VAPI CIRCLE,, VAPI

In the result, the appeal of the Assessee for AY 2005-06 is partly allowed for statistical purposes

ITA 327/SRT/2018[2011-12]Status: DisposedITAT Surat19 Dec 2022AY 2011-12

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.323 To 327/Srt/2018 Ays: (2005-06 To 2007-08, 2009-10 & 2011-12) (Virtual Court Hearing) N. Core Cables, Vs. The Acit, Vapi Circle, Gala No.7, Plot No.10, Primier Vapi. Industrial Area, Kachigam, Daman-396210, U.T Of Daman & Diu. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaefn7954N (Appellant) (Respondent) आयकर अपील सं./Ita No.689/Srt/2018 Assessment Year: (2007-08) (Virtual Court Hearing) N. Core Cables, Vs. The Acit, Vapi Circle, Gala No.7, Plot No.10, Primier Vapi. Industrial Area, Kachigam, Daman-396210, U.T Of Daman & Diu. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaefn7954N (Appellant) (Respondent) Assessee By Shri A. Gopalkrishnan, Ca Respondent By Shri Vinod Kumar, Sr. Dr 10/10/2022 Date Of Hearing Date Of Pronouncement 19/12/2022

Section 143(3)Section 80I

…party premises using their machinery under the supervision and control of an assessee amounts to manufacturing by the industrial undertaking. While holding as such the honorable court followed its own decision in the case of CIT v. Neo Pharma (P.) Ltd. [1982] 137 ITR 879 and Calcutta High Court in the case of Addl. CIT v. A. Mukherjee & Co. (P.) Ltd. [1978] 113 ITR 718. The relevant findings of the Hon`ble Court is reproduced below: “3. In our judgment, the answer to this question is squarely covered by the judgment of our High Court in the case of CIT v. Neo Pharma (P.) Ltd.[1982] 137 ITR 879. In this case, it w…

N CORE CABLES,DAMAN vs. THE ACIT,VAPI CIRCLE,, VAPI

In the result, the appeal of the Assessee for AY 2005-06 is partly allowed for statistical purposes

ITA 324/SRT/2018[2006-07]Status: DisposedITAT Surat19 Dec 2022AY 2006-07

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.323 To 327/Srt/2018 Ays: (2005-06 To 2007-08, 2009-10 & 2011-12) (Virtual Court Hearing) N. Core Cables, Vs. The Acit, Vapi Circle, Gala No.7, Plot No.10, Primier Vapi. Industrial Area, Kachigam, Daman-396210, U.T Of Daman & Diu. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaefn7954N (Appellant) (Respondent) आयकर अपील सं./Ita No.689/Srt/2018 Assessment Year: (2007-08) (Virtual Court Hearing) N. Core Cables, Vs. The Acit, Vapi Circle, Gala No.7, Plot No.10, Primier Vapi. Industrial Area, Kachigam, Daman-396210, U.T Of Daman & Diu. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaefn7954N (Appellant) (Respondent) Assessee By Shri A. Gopalkrishnan, Ca Respondent By Shri Vinod Kumar, Sr. Dr 10/10/2022 Date Of Hearing Date Of Pronouncement 19/12/2022

Section 143(3)Section 80I

…party premises using their machinery under the supervision and control of an assessee amounts to manufacturing by the industrial undertaking. While holding as such the honorable court followed its own decision in the case of CIT v. Neo Pharma (P.) Ltd. [1982] 137 ITR 879 and Calcutta High Court in the case of Addl. CIT v. A. Mukherjee & Co. (P.) Ltd. [1978] 113 ITR 718. The relevant findings of the Hon`ble Court is reproduced below: “3. In our judgment, the answer to this question is squarely covered by the judgment of our High Court in the case of CIT v. Neo Pharma (P.) Ltd.[1982] 137 ITR 879. In this case, it w…

N CORE CABLES,DAMAN vs. THE ACIT,VAPI CIRCLE,, VAPI

In the result, the appeal of the Assessee for AY 2005-06 is partly allowed for statistical purposes

ITA 323/SRT/2018[2005-06]Status: DisposedITAT Surat19 Dec 2022AY 2005-06

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.323 To 327/Srt/2018 Ays: (2005-06 To 2007-08, 2009-10 & 2011-12) (Virtual Court Hearing) N. Core Cables, Vs. The Acit, Vapi Circle, Gala No.7, Plot No.10, Primier Vapi. Industrial Area, Kachigam, Daman-396210, U.T Of Daman & Diu. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaefn7954N (Appellant) (Respondent) आयकर अपील सं./Ita No.689/Srt/2018 Assessment Year: (2007-08) (Virtual Court Hearing) N. Core Cables, Vs. The Acit, Vapi Circle, Gala No.7, Plot No.10, Primier Vapi. Industrial Area, Kachigam, Daman-396210, U.T Of Daman & Diu. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaefn7954N (Appellant) (Respondent) Assessee By Shri A. Gopalkrishnan, Ca Respondent By Shri Vinod Kumar, Sr. Dr 10/10/2022 Date Of Hearing Date Of Pronouncement 19/12/2022

Section 143(3)Section 80I

…party premises using their machinery under the supervision and control of an assessee amounts to manufacturing by the industrial undertaking. While holding as such the honorable court followed its own decision in the case of CIT v. Neo Pharma (P.) Ltd. [1982] 137 ITR 879 and Calcutta High Court in the case of Addl. CIT v. A. Mukherjee & Co. (P.) Ltd. [1978] 113 ITR 718. The relevant findings of the Hon`ble Court is reproduced below: “3. In our judgment, the answer to this question is squarely covered by the judgment of our High Court in the case of CIT v. Neo Pharma (P.) Ltd.[1982] 137 ITR 879. In this case, it w…

DCIT, CIRCLE-1, THANE, THANE vs. M/S ACE PLASTICS , MUMBAI

ITA 947/MUM/2022[2011-12]Status: DisposedITAT Mumbai30 Nov 2022AY 2011-12

Bench: Shri Kuldip Singhassessment Year: 2011-12

For Appellant: Shri Ajay Singh, A.RFor Respondent: Shri Krishna Kumar, D.R
Section 143(3)Section 148Section 80Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “SMC”, MUMBAI BEFORE SHRI KULDIP SINGH, JUDICIAL MEMBER Assessment Year: 2011-12 Dy. Commissioner of M/s. ACE Plastics, Income Tax, 19-A, Mira Industrial Circle -1, Estate, 6th Floor, Western Express Vs. Ashar IT Park, Highway, Room No.22, B-Wing, Mira Road (East), Wagle Industrial Estate, Thane – 401 101 Road No.16Z, PAN: AAFFA1338Q Thane (West)-401 101 (Appellant) (Respondent) Present for: Assessee by : Shri Ajay Singh, A.R. Revenue by : Shri Krishna Kumar, D.R. Date of Hearing : 16 . 11 . 2022 Date of Pronouncement : 30 . 11 . 2022 O R D E R Per : Kuldip Si…

THE COMMISSIONER OF INCOME TAX vs. M/S. LAILA NUTRACEUTICALS

ITTA/192/2017HC Andhra Pradesh24 Aug 2022

Bench: C.PRAVEEN KUMAR,A V RAVINDRA BABU

Section 260

…argument of the learned Standing Counsel for the Income Tax that there was no manufacturing process atall may not be correct. 18 23. some to the decisions of the 'I sMai s’ i ‘ 188 ITR 370 (All) 2 137 ITR 329 (MP) ’ 196 ITR 813 (Bom) 86 TTJ 298 (Mum) 137 ITR 879 (Mum) ®338 ITR 290 (Delhi) UP State Agro Industrial Corporation Limited^, Madhya Pradesh High Court in CWT v. Premlatha Bai^, Bombay High Court in CIT v. Penwait India LimitetP, Sunrise Metal Industries v. ITCP, CIT v. Neo Pharma Private Limited^ and the decision of the Delhi High Court in CIT v. Continental Engines Limited^, it cannot be…

THE COMMISSIONER OF INCOME TAX vs. M/S LAILA NUTRACEUTICALS

ITTA/121/2017HC Andhra Pradesh24 Aug 2022

Bench: C.PRAVEEN KUMAR,A V RAVINDRA BABU

Section 260

…argument of the learned Standing Counsel for the Income Tax that there was no manufacturing process atall may not be correct. 18 23. some to the decisions of the 'I sMai s’ i ‘ 188 ITR 370 (All) 2 137 ITR 329 (MP) ’ 196 ITR 813 (Bom) 86 TTJ 298 (Mum) 137 ITR 879 (Mum) ®338 ITR 290 (Delhi) UP State Agro Industrial Corporation Limited^, Madhya Pradesh High Court in CWT v. Premlatha Bai^, Bombay High Court in CIT v. Penwait India LimitetP, Sunrise Metal Industries v. ITCP, CIT v. Neo Pharma Private Limited^ and the decision of the Delhi High Court in CIT v. Continental Engines Limited^, it cannot be…

THE COMMISSIONER OF INCOME TAX, VIJAYAWADA vs. M/S LAILA NUTRACEUTICALS, VIJAYAWADA

ITTA/25/2017HC Andhra Pradesh24 Aug 2022

Bench: C.PRAVEEN KUMAR,A V RAVINDRA BABU

Section 260

…argument of the learned Standing Counsel for the Income Tax that there was no manufacturing process atall may not be correct. 18 23. some to the decisions of the 'I sMai s’ i ‘ 188 ITR 370 (All) 2 137 ITR 329 (MP) ’ 196 ITR 813 (Bom) 86 TTJ 298 (Mum) 137 ITR 879 (Mum) ®338 ITR 290 (Delhi) UP State Agro Industrial Corporation Limited^, Madhya Pradesh High Court in CWT v. Premlatha Bai^, Bombay High Court in CIT v. Penwait India LimitetP, Sunrise Metal Industries v. ITCP, CIT v. Neo Pharma Private Limited^ and the decision of the Delhi High Court in CIT v. Continental Engines Limited^, it cannot be…

THE COMMISSIONER OF INOCME TAX vs. M/S LAILA NUTRACEUTICALS

ITTA/259/2015HC Andhra Pradesh24 Aug 2022

Bench: C.PRAVEEN KUMAR,A V RAVINDRA BABU

Section 260

…argument of the learned Standing Counsel for the Income Tax that there was no manufacturing process atall may not be correct. 18 23. some to the decisions of the 'I sMai s’ i ‘ 188 ITR 370 (All) 2 137 ITR 329 (MP) ’ 196 ITR 813 (Bom) 86 TTJ 298 (Mum) 137 ITR 879 (Mum) ®338 ITR 290 (Delhi) UP State Agro Industrial Corporation Limited^, Madhya Pradesh High Court in CWT v. Premlatha Bai^, Bombay High Court in CIT v. Penwait India LimitetP, Sunrise Metal Industries v. ITCP, CIT v. Neo Pharma Private Limited^ and the decision of the Delhi High Court in CIT v. Continental Engines Limited^, it cannot be…

DCIT, CHANDIGARH vs. M/S SPRAY ENGINEERING DEVICES LTD., CHANDIGARH

In the result, the appeal of the Revenue is hereby dismissed

ITA 369/CHANDI/2015[2011-12]Status: DisposedITAT Chandigarh03 Apr 2018AY 2011-12

Bench: Shri Sanjay Garg & Dr. B.R.R. Kumar

For Appellant: NoneFor Respondent: Sh. Manjit Singh, Sr.DR
Section 115JSection 14ASection 80I

…. ....Further, most of the work was done by the sub-contractors under the supervision of the employees of the assessee. Therefore, the question of showing power expenses did not arise. In this connection, it has been held in CIT v. Neo Pharma (P.) Ltd. [1982] 137 ITR 879 (Bom.) that where the manufacturing activity has been carried on by another concern under the supervision of qualified staff of the assessee then such activity can be treated as activity of the assessee. On the basis of that decision it was to be held that the assessee had been carrying on manufacturing activity." 64. In respect of the deduction…

A.C.I.T. CENTRAL CIRCLE-20, MUMBAI vs. ANKUR DRUGS & PHARMA LTD., MUMBAI

In the result appeal of the Revenue in I

ITA 7529/MUM/2011[2006-07]Status: DisposedITAT Mumbai27 Feb 2018AY 2006-07

Bench: Shri Joginder Singh & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No. 7529/Mum/2011 (नििाारण वर्ा / Assessment Year: 2006-07)

For Appellant: Shri. Vijay MehtaFor Respondent: Shri. R.P Meena, CIT DR
Section 132(1)Section 139(1)Section 153ASection 271(1)(c)Section 80I

…C. The learned counsel for the assessee relied upon the decision of Hon’ble Bombay High Court in the case of CIT v. Penwalt India Limited (1992)196 ITR 813(Bom. HC), decision of Hon’ble Bombay High Court in the case of CIT V. Nee Pharma Private Limited (1982) 137 ITR 879(Bom.) as well the case of CIT v. Anglo French Drug Co.(Eastern) Limited reported in (1991) 191 ITR 92(Bom) . The learned counsel for the assessee also relied upon the decision of ITAT, Mumbai in the case of Sunrise Metal Industries v. ITO reported in (2004) 89 ITD 406(Mum.). It was submitted that there was a loan licence agreement with Vaibhav He…

HERO MOTOCORP LIMITED,NEW DELHI vs. JCIT, NEW DELHI

In the result appeal of the assessee in ITA No

ITA 1545/DEL/2015[2010-11]Status: DisposedITAT Delhi24 Oct 2016AY 2010-11

Bench: Sh. I. C. Sudhir & Shri Prashant Maharishihero Motocorp Limited, Jcit, 34, Basant Lok, Vasant Range-1, New Delhi Vs. Vihar, New Delhi Pan: Aaach0812J (Appellant) (Respondent) Dcit, M/S. Hero Moto Corp. Circle-11(1), Ltd., 34, Community Vs. New Delhi Centre, Basant Lok, Vasant Vihar, New Delhi-110057 (Appellant) (Respondent) Dcit, M/S. Hero Moto Corp. Circle-11(1), Ltd., 34, Community

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. NC Sawain, CIT DR
Section 143Section 143(3)Section 144CSection 92C

…anufacture or production of relevant goods. Reference, in this regard, can be made to the following decisions: - Addl. CIT vs. A. Mukherjee and Co. (P) Ltd.: 113 ITR 718 (Cal.) Griffon Laboratories Pvt. vs. CIT: 119 ITR 145 - (Cal.) CIT v. Neo Phrama P. Ltd.: 137 ITR 879 (Bom.) - - CIT v. Anglo French Drug Co. (Eastern) Ltd. : 199 ITR 92 (Bom.) India TyreAnd Rubber Co. (India) Pvt. Limited. - vs. CIT: 210 ITR 409 (Bom.) CIT v. Penwalt India Ltd.: 196 ITR 813 (Bom.) - - Oriental Longman Ltd. vs. CIT: 130 ITR 477 (Del.) - CIT v. Acrow India Ltd.: 188 ITR 485 (Bom.) CIT vs. Elgi Ultra Industries Ltd. : 25 - taxmann.…

DCIT CC 1, MUMBAI vs. FOREVER PRECIOUS JEWELERY & DIAMOND LTD, MUMBAI

In the result, this appeal is partly allowed

ITA 4295/MUM/2013[2007-08]Status: DisposedITAT Mumbai30 Sept 2016AY 2007-08

Bench: Shri G S Pannu&Shrisanjay Garg

For Appellant: Shri G M Doss– CIT -DRFor Respondent: S/Shri F V Irani& Rajesh Shah
Section 10ASection 143(3)Section 68

…utsourced to the third party and, therefore, the assessee was not entitled to claim deduction u/s. 10AA of the Act. The learned AR, on the other hand, while relying on the decision of the Hon’ble Bombay High Court in the case of Neo Pharma Private Ltd. [1982] 137 ITR 879 has contended that under an agreement the assessee had got the articles manufactured in another company under its direct supervision and quality control and the raw material was also supplied by the assessee. Under such circumstances the risk was of the assessee for the entire operation undertaken and the products manufactured at the assessee’s c…

DCIT CEN CIR 1, MUMBAI vs. FOREVER PRECIOUS JEWELLRY & DIAMONDS LTD, MUMBAI

In the result, this appeal is partly allowed

ITA 3783/MUM/2011[2007-08]Status: DisposedITAT Mumbai30 Sept 2016AY 2007-08

Bench: Shri G S Pannu&Shrisanjay Garg

For Appellant: Shri G M Doss– CIT -DRFor Respondent: S/Shri F V Irani& Rajesh Shah
Section 10ASection 143(3)Section 68

…utsourced to the third party and, therefore, the assessee was not entitled to claim deduction u/s. 10AA of the Act. The learned AR, on the other hand, while relying on the decision of the Hon’ble Bombay High Court in the case of Neo Pharma Private Ltd. [1982] 137 ITR 879 has contended that under an agreement the assessee had got the articles manufactured in another company under its direct supervision and quality control and the raw material was also supplied by the assessee. Under such circumstances the risk was of the assessee for the entire operation undertaken and the products manufactured at the assessee’s c…

DCIT CEN CIR 1, MUMBAI vs. FOREVER PRECIOUS JEWELLERY & DIAMONDS LATD, MUMBAI

In the result, this appeal is partly allowed

ITA 3776/MUM/2011[2006-07]Status: DisposedITAT Mumbai30 Sept 2016AY 2006-07

Bench: Shri G S Pannu&Shrisanjay Garg

For Appellant: Shri G M Doss– CIT -DRFor Respondent: S/Shri F V Irani& Rajesh Shah
Section 10ASection 143(3)Section 68

…utsourced to the third party and, therefore, the assessee was not entitled to claim deduction u/s. 10AA of the Act. The learned AR, on the other hand, while relying on the decision of the Hon’ble Bombay High Court in the case of Neo Pharma Private Ltd. [1982] 137 ITR 879 has contended that under an agreement the assessee had got the articles manufactured in another company under its direct supervision and quality control and the raw material was also supplied by the assessee. Under such circumstances the risk was of the assessee for the entire operation undertaken and the products manufactured at the assessee’s c…

DCIT CEN CIR 1, MUMBAI vs. FOREVER PRECIOUS JEWELLERY & DIAMONDS LATD, MUMBAI

In the result, this appeal is partly allowed

ITA 3775/MUM/2011[2005-06]Status: DisposedITAT Mumbai30 Sept 2016AY 2005-06

Bench: Shri G S Pannu&Shrisanjay Garg

For Appellant: Shri G M Doss– CIT -DRFor Respondent: S/Shri F V Irani& Rajesh Shah
Section 10ASection 143(3)Section 68

…utsourced to the third party and, therefore, the assessee was not entitled to claim deduction u/s. 10AA of the Act. The learned AR, on the other hand, while relying on the decision of the Hon’ble Bombay High Court in the case of Neo Pharma Private Ltd. [1982] 137 ITR 879 has contended that under an agreement the assessee had got the articles manufactured in another company under its direct supervision and quality control and the raw material was also supplied by the assessee. Under such circumstances the risk was of the assessee for the entire operation undertaken and the products manufactured at the assessee’s c…

THE INCOME TAX OFFICER,WARD-4(3) vs. FOREVER PRECIOUS JEWELLERY & DAIMOND LTD.,,

In the result, this appeal is partly allowed

ITA 1142/AHD/2010[2006-07]Status: DisposedITAT Mumbai30 Sept 2016AY 2006-07

Bench: Shri G S Pannu&Shrisanjay Garg

For Appellant: Shri G M Doss– CIT -DRFor Respondent: S/Shri F V Irani& Rajesh Shah
Section 10ASection 143(3)Section 68

…utsourced to the third party and, therefore, the assessee was not entitled to claim deduction u/s. 10AA of the Act. The learned AR, on the other hand, while relying on the decision of the Hon’ble Bombay High Court in the case of Neo Pharma Private Ltd. [1982] 137 ITR 879 has contended that under an agreement the assessee had got the articles manufactured in another company under its direct supervision and quality control and the raw material was also supplied by the assessee. Under such circumstances the risk was of the assessee for the entire operation undertaken and the products manufactured at the assessee’s c…

Commissioner of Income Tax – I

ITA/551/2013HC Delhi05 Feb 2015
Section 10B

…a contractor of the assessee. In the said case, the High Court was examining whether the assessee was engaged in manufacture or processing of goods. The same view has been taken by the Bombay High Court in the case of CIT v. Neo Pharma Private Ltd. [1982] 137 ITR 879 (Bom.), CIT vs. Acrow India Ltd. [1991] 188 ITR 485 (Bom.) and CIT vs. Anglo French Drug Co. (Eastern) Ltd. (1991) 191 ITR 92 (Bom.). In these cases, it has been held that assessee was not a trader but a manufacturer/processor engaged in manufacturing and processing activities, when these activities were undertaken by a third person, under t…

Commissioner of Income Tax

The appeal is disposed of

ITA/141/2002HC Delhi22 Dec 2014
Section 260ASection 80Section 80HSection 88H

…or processing of 2014:DHC:7311-DB ITA 141/2002 Page 18 of 19 goods. The same view has been taken by the Bombay High Court in the case of CIT v. Neo Pharma Private Ltd. [1982] 137 ITR 879 (Bom.), CIT vs. Acrow India Ltd. [1991] 188 ITR 485 (Bom.) and CIT vs. Anglo French Drug Co. (Eastern) Ltd. (1991) 191 ITR 92 (Bom.). In these cases, it has been held that assessee was not a trader but a manufacturer/processor engaged in manufacturing and processing activities, when these activities were undertaken by a third person, und…