1987 (4) TMI 93

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..... 961. The admitted facts are that the assessee is engaged in the business of the data processing, The services are rendered mainly for M/s. Quality Biscuits Co. For that purpose, the assessee had purchased a computer for Rs. 4,61,760 and claimed investment allowance of Rs. 1,15,429 thereon. The Income-tax Officer on the directions of the Inspecting Assistant Commissioner held that data processing d .....

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..... entitled to any relief. 3. On a consideration of rival submissions, we are of the opinion that the assessee is entitled to succeed. Under s. 32A the assessee is entitled to the investment allowance if the machinery is installed in an industrial undertaking for the purpose of business of construction, manufacture or production of any article or thing. The only point in dispute between the parti .....

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..... d that such print-outs are things produced by the assessee. We may refer to the case of CIT v. Ajay Printery (P.) Ltd. [1965] 58 ITR 811 (Guj.) where it was held that printing of balance sheets by itself would constitute a manufacturing activity. In that background, the data processed and printed-out would certainly be a thing produced by the assessee even if not a thing manufactured by the assess .....

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