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1982 (11) TMI 43

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..... in this income-tax reference is a company called M/s. 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 it .....

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..... ed to the development rebate at the higher rate in 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 i .....

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..... that the assessee also manufactures internal combustion 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 applicabil .....

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..... motor trucks and other vehicles. The process by 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 .....

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