Extraction if amounts to manufacture or production?

Does extraction and processing of iron ore  amount  manufacture or production of any article or thing?

Production means amongst other things that which is produced; a thing that results from any action, process or effort, a product; a product of human activity or effort”. From the wide definition of the word “production”, it has to follow that mining activity for the purpose of production of mineral ores would come within the arnbit of the word “production” since ore is “a thing”, which is the result of human activity or effort.

In CIT v. N. C. Budharaja and Co. (1993) 204 ITR 412 (SC): AIR 1993 SC 2529: 1994 SCC Supl. (1) 280 it was held that the word ,production” is much wider than the word “manufacture”. It was said (page 423) :

“The word production has a wider connotation than the word manufacture. While every manufacture can be characterized as production, every production need not amount to manufacture …. Continue reading “What is the meaning of word “production” and “manufacture”?” →