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2002 (10) TMI 40 - HC - Income Tax"1. Whether, on the facts and in the circumstances of the case, the Tribunal was correct in not granting deduction under section 32A of the Income-tax Act, 1961, for the assessment year 1986-87 and deduction under section 80-I for the assessment year 1987-88 ?" - The assessee is only trading in photographic colour papers as a wholesaler and slit the already manufactured and produced photographic paper into required sizes to suit the requirement of its customers and in easily marketable sizes. Therefore, the slitting of the bigger roll into marketable smaller rolls or sizes is an integral part of the trading activity of the assessee. - In view of the above discussion with particular reference to the activity carried on by the assessee, and in the light of the decisions above referred to, we are of the considered view that on the facts and circumstances of this case, the assessee cannot be regarded as being engaged in the business of manufacture or production of an article or thing. The question is answered in favour of the Revenue and against the assessee.
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