1982 (3) TMI 147

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... clause (vi) of section 32(1) of the Income-tax Act, 1961 ("the Act"). The previous year of the assessee ended 23-10-1976. It started its business from 1-4-1976. The ITO took the view that there was no business of manufacture or production within the meaning of section 32(1)(vi) of the assessee during the previous year, relevant to the year under appeal, and, therefore, the assessee was not entitle .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... ction of the AAC is that the assessee started the manufacturing work during the previous year relevant to the year under appeal and that he had shifted to anodising work. So the AAC accepted that the assessee had carried on the business of manufacturing during the year under appeal. The question is whether section 32(1)(vi) enjoins upon the assessee to continue the business of manufacture for the .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... table. He stated that the manufacturing remained merely as testing manufacturing. When a machinery is useful for several purposes including manufacture of some items, it cannot be said that main business was not of manufacture, because the assessee started anodising work in the present instance. The order of starting the business will not determine the principal or the subsidiary business. The b .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X