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TMI Blog1982 (11) TMI 43X X X X Extracts X X X X X X X X Extracts X X X X ..... . Simpson and Co. Ltd., Madras. It is engaged in the construction of bodies for buses, motor trucks, etc., on chassis supplied by the customers. For the purposes of this business, the assessee had purchased various items of new machinery like 1 3 HP Kirloskar motor, brake press and various other machines and instruments. On the cost of these items of machinery which were newly purchased and newl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... respect of machinery installed in the body building and light engineering section of the assessee-company ? " Before us, the claim of the assessee for higher development rebate was debated at the Bar in terms of as many as three items in Sch. V to the I.T. Act. Before noticing the relevant items, we may observe that the higher development rebate is granted by Parliament under s. 33(1)(b)(B)(i) of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... stion engines apart from being engaged in the construction of bus bodies. We are, therefore, satisfied that in respect of machinery purchased and installed by the assessee for the manufacture of internal combustion engines, the assessee will be entitled to the higher development rebate. The dispute before us, however, centers round the applicability of entries 10 and 20. Under entry 10, the mach ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... which the assessee makes a mere chassis into a full-fledged motorbus or a truck is variously described. In the commercial parlance sometimes it is called manufacture of bus bodies. Sometimes it is referred to as construction of, or building body on the chassis, of a bus. The process is popularly described as " bus body building ". Whether it is the one or the other description which is linguistica ..... X X X X Extracts X X X X X X X X Extracts X X X X
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