TMI Blog1980 (12) TMI 69X X X X Extracts X X X X X X X X Extracts X X X X ..... The firm purchases paddy and converts it into rice and sells it. The assessee claimed relief due to it under ss. 80J, 80HH and 32A. The ITO held that the relief under these sections cannot be given as the assessee firm does not satisfy the conditions laid down therein. The assessee has to either manufacture or produce articles. He held the assessee firm does not produce rice as such except that i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... m Plantations Ltd. Kottayam AIR 1969 SC 930 and the case of Singh Engineering Works Pvt. Ltd. vs. CIT 1978 CTR (All) 201 : (1979) 119 ITR 891 (All). 4. The Deptl. Representative, on the other hand, relied on the orders below. 5. The assessee claims relief under s. 32A, 80J and 80HH. Sec. 32A(2)(ii) requires that the machinery or plant should be used in the business of construction, manufactu ..... X X X X Extracts X X X X X X X X Extracts X X X X
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