Tribunal held that converting raw coffee beans which were not fit for human consumption as such to liquid coffee which was fit for human consumption was a manufacturing activity, as it was an irreversible process producing a different marketable product fit for human consumption. It came to that position by storing, drying of coffee, hulling, pealing, polishing, grading, colour sorting, garbling and manual grading, out-turning of garbled coffee and bulking. This being an irreversible process, there was a change in the chemical composition of the product. Alternatively, it could not be said that this was a processing. It amounts to production and manufacture of a distinct commercial product different from the original product. Thus the coffee making machine, vending machine, express kiosks which were used for such activities, were machines on which the assessee was entitled to additional depreciation. ( AY.2013-14, 2014-15)
Dy. CIT v. Coffee Day Global Ltd. (2020) 79 ITR 322 (Bang) (Trib)
S.32: Depreciation — Additional depreciation —Manufacturing – Coffee making machine, vending machine and express Kiosks used for converting raw coffee beans into liquid coffee fit for human consumption —Entitled to additional depreciation.[ S.32(1)(iia)]