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2019 (3) TMI 1308 - HC - Income TaxDeduction u/s 80IA - Manual processing - least consumption of electricity - manufacture of a herbal product Bandruff by a manual process with the use of some chemicals and small machinery - no new industrial unit, machinery or infrastructure as claimed - Whether Tribunal was right in holding that the Assessee was entitled to the benefit of Section 80IA even if it does not do the manufacturing process on its own but gets it done by third parties? - HELD THAT:- The manufacture of a herbal product Bandruff by a manual process with the use of some chemicals and small machinery can also amount to manufacture or production of a different commercial article which is the basic requirement under Section 80IA of the Act. The purpose of the said provision is to encourage industrialisation and investment in an industry. The purchase of plant and machinery, and consumption of electricity are not mandatory requirement as was thought by the learned Assessing Authority in the present case. The learned Tribunal after describing the said manufacture / production process of the herbal product was, in our opinion, perfectly justified in holding that the same amounted to manufacture of a different commercial article and that therefore, the Assessee was entitled to the deduction under Section 80IA - decided against revenue
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