Dismissing the appeal of the revenue the Court held that,purchase of semi-finished garments and making them export worthy, constitute manufacture hence entitle to exemption . Followed, Aspinwall and Co Ltd. v. CIT ( 2001) 251 ITR 323 (SC)(AY. 2004 -05)
CIT v. A. P. Export. (2019) 410 ITR 168/ 175 DTR 66 / 307 CTR 550(Cal) (HC)
S. 10B : Export oriented undertakings–Manufacture- Purchase of semi-finished garments and making them export worthy-Constitute manufacture – Entitle to exemption.