COMMISSIONER OF INCOME TAX,TRIVANDRUM vs RELISH FOODS

The Supreme Court addressed the issue of whether the assessee's activities constituted 'production' under Section 80HH of the Income-Tax Act, 1961. The Court held that merely peeling and freezing shrimps does not amount to manufacturing or production, aligning with the precedent set in Sterling Foods v. The State of Karnataka. Consequently, the High Court's ruling in favor of the assessee was reversed, denying the exemption claim under Section 80HH.