Dismissing the appeals, that the process of garbling to make pepper edible did not give rise to a different commodity distinct from the raw pepper purchased. The assessee was not entitled to deduction under section 10B . ( AY. 2003-04, 2005-06 )
Nishant Export v. ACIT (2018) 401 ITR 401/ 168 DTR 157 / 303 CTR 624 (Ker) (HC)
S. 10B: Export oriented undertakings – Manufacture or processing — Garbling pepper to make it edible — No new product emerges — Not entitled to deduction .