9911796707
TMI Blog1988 (11) TMI 55X X X X Extracts X X X X X X X X Extracts X X X X ..... Co. (P.) Ltd., is company engaged in the procurement of orders for the manufacture of railway track and other items. On July 1, 1974, it took over Bhushan Steel Rolling Mills and claimed deduction under section 80J of the Income-tax Act, 1961 (hereinafter referred to as "the Act"), of Rs. 1,16,833 on this account. The Income-tax Officer allowed only proportionate relief under section 80J(3) of th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , it was held by the High Court of Madras that "the relief of 6 per cent. of the capital employed under section 80J of the Act is intended for grant of relief for the full year and not only for part of the year in proportion to the period during which the machinery was used." In this behalf, it was further observed at p. 287 : "It is also a well-settled principle of construction that in construing ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... [1980] 122 ITR 283, as also the similar view taken by the High Court of Karnataka in CIT v. Mysore Petro-chemical Ltd. [1984] 145 ITR 416 and has issued Circular No. 37, dated March 3, 1984, that, "the deduction under section 80J should not be reduced proportionately with reference to the period for which the business of the undertaking, shop or hotel was not carried on during the relevant previo ..... X X X X Extracts X X X X X X X X Extracts X X X X
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