M/S. INDIA CINE AGENCIES vs COMMNR. OF INCOME TAX, MADRAS

The Supreme Court addressed the interpretation of 'manufacture' under Section 32AB, Section 80HH, and Section 80I of the Income Tax Act, 1961, determining that the conversion of jumbo rolls of photographic films into smaller sizes constitutes 'manufacture' as it results in a commercially distinct product. The Court clarified that a change must render the original commodity unrecognizable as the same article, thus qualifying for tax benefits. The appeals were allowed, overturning the High Court's decision favoring the revenue.