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2018 (11) TMI 382 - AT - Income TaxEligibility for additional depreciation u/s 32(1)(iia) on plant and machineries relating to Seed Division - Held that:- If we examine the facts of the instant case in the light of the judgment of the Hon'ble Bombay High Court in the case of Jalna Seeds Processing and Refrigeration Co. Ltd. [2000 (2) TMI 56 - BOMBAY HIGH COURT], an irresistible conclusion which can be drawn is that the pre-processed seeds procured by the assessee are quite different in its usage and marketability qua the final product. The various stages of processing undertaken by the assessee, which were canvassed by the assessee before the Assessing Officer also, have not been disputed by the Revenue at any stage. Thus,the instant activity of the assessee is held to be an activity of manufacturing; thus, assessee is eligible for additional depreciation u/s 32(1)(iia) of the Act on its plant and machineries relating to Seed Division. - decided in favour of assessee.
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