versus
Sections 80C (2) (a) (ii), 143B, 50 (5) and 62 CBR Circular No. 12, 1991 30 30 1991 CBR Circular No. 1 (14) TPH / 91, Dated 29 6 1991 CNR Circular No. Income Tax Ordinance Under section 50 (5) of 1979, at the import stage 1 (42) (WHT) / 2000, the tax CNG on the income of certain contractors and importers of 30th 2001 Kits and cylinder taxes were withheld at the import stage. Such import kits and cylinders were claimed by Assisi to be made of kits and cylinders based on the imposition of such kits and cylinders on the vehicles and instead of filing a statement under Section 143B of the Income Tax Ordinance 1979 Was counted. The officer has declared the amount of tax withheld under section 50 (5) of the Income Tax Ordinance 1979, on the basis of Circular No. 12 of the Central Board of Revenue, on the first appellant of 30 30 1991, imports of kits and cylinders. Gave. The Authority canceled the assessment made under section 80C of the Income Tax Ordinance, 1979 and the Assisi was considered to be a gas kits and a cylinder. Accuracy was not included in or involved in the manufacture of gas kits and cylinders, while the installation of these items in motor vehicles could not be named manufacture. The only criterion for manufacturing was that in this process a new and marketable product should come into being, which should be separate and different from the feed in the material, there were no such activities, whereas without manufacturing activities, the raw material There is no question of using The initial Appellate Authority order was vacated and the Assessing Officer restored by the Appellate Tribunal
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