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2021 (3) TMI 935 - AT - Income TaxAdditional depredation u/s 32 (1)(iia) - process of delivery of CNG to automobiles at the CNG filling centres - Fulfilment of mandate of manufacture or production or an article or thing which is mandatory requirement for claiming additional depredation u/s 32 (1)(iia) - CIT (A) confirmed the addition holding that the company is not into manufacturing or production of CNG - HELD THAT:- As decided in the case Central UP Gas Ltd. [2016 (12) TMI 814 - ALLAHABAD HIGH COURT] Compressed natural gas in its compressed form has a distinct identity and character and use. It is settled law of the Apex Court in the case of Income Tax Officer Vs.Arihant Tiles and Marbles P. LTD. reported in [2009 (12) TMI 1 - SUPREME COURT] that when a commodity acquires a distinct name, use and commercial identity, it would acquire the trait of 'manufacture'. The question is answered in favour of the assessee
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