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Issues:
1. Whether the assessee is engaged in the manufacture or production of any article or thing and is entitled to investment allowance and deduction under section 80-I for the assessment year 1985-86. Analysis: The case involved questions referred by the Income-tax Appellate Tribunal regarding the assessee's eligibility for deduction under section 80-I of the Income-tax Act, 1961. The Assessing Officer initially denied the deduction, stating that the assessee was not engaged in any manufacturing activity. However, the Commissioner of Income-tax (Appeals) allowed the deduction, which was further contested before the Appellate Tribunal. The Tribunal found that the assessee, involved in masticating rubber, was engaged in manufacturing as the mastication process resulted in a commercially different end-product. The Tribunal referred to a previous decision by the Madras High Court to support its conclusion. The High Court noted that the Madras High Court's decision did not directly address whether the masticating process amounted to manufacturing. The Madras High Court's decision primarily focused on whether the establishment of a new unit was an extension or reconstruction of the existing business. The High Court emphasized the need for a clear finding on the compounds added in the masticating process and the nature of the end-product to determine if the assessee qualified for investment allowance under section 80-I. In light of the lack of a clear finding on the compounds added and the nature of the end-product, the High Court remitted the matter back to the Appellate Tribunal. The Tribunal was directed to establish clear findings on the chemicals used in the masticating process and the precise nature of the end-product. Only after obtaining these findings, the Tribunal would determine whether the assessee was engaged in manufacturing, thus eligible for the investment allowance under section 80-I of the Act.
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