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2011 (11) TMI 502 - AT - Income TaxAdditional depreciation - disallowance as the machinery is not used for any manufacturing or production activity and no new product came into existence - assessee engaged in the business of exporting of safety razor blades and twin track shaving system - Held that:- The process carried on raw grounded blades purchased from market to make them commercially viable certainly amounts to manufacture. The raw grounded blades could not be used for shaving thus cannot be commercially viable product, which is salable in the market. The final product manufactured by assessee is commercially new and different article having a distinctive name character and use. Thus, assessee is manufacturer and is entitled for additional depreciation u/s. 32(1)(iia) on additional machineries purchased and used for packaging - Decided in favour of assessee. Wastage in production process - Disallowance as there is no manufacturing activity - Held that:- This amount has already been credited to P&L Account by the assessee in its final accounts and already offered this amount for taxation and same cannot be taxed again - considering the findings of CIT(A) upholding the activity of the assessee as manufacturing, hence on this count also the assessee succeeds - Decided in favor of assessee
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