9911796707
TMI Blog1986 (6) TMI 64X X X X Extracts X X X X X X X X Extracts X X X X ..... customers M/s Mukund Iron and Steel Ltd. supply rough castings to the assessee for carrying out some job work like grinding, smoothing and levelling of the surface. After carrying out the work, the assessee returns the articles of M/s Mukund Iron Steel Ltd. For this type of work of fabrication the assessee installed certain plant and machinery on which investment allowance under s. 32A has been ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing to law. 4. The assessee is aggrieved and has come up in appeal before us. Shri V.H. Patil, ld. counsel of the assessee vehemently objected to the order of the CIT under s. 263. According to him the issue is squarely covered by the decision of the Madras High Court in the case of Perfect liners vs. CIT (1983) 142 ITR 654 (Mad). The ld. counsel also relied on the decisions of the special Benc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... understood in a wide sense. After the rough casting was polished, the product was a new product which was utilised as component in internal combustion. Similar point came up for consideration before the Special Bench of the Tribunal in the case of Thiagaraja industries and on similar facts the Tribunal held that the assessee was entitled to investment allowance under s. 32A of the IT Act. Shri Pa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing a job work of fabrication of engineering goods, grinding and other similar type of work. Identical case came up before the Tribunal (Special Bench) in the case of Thiagaraja Industries. The Special Bench carefully examined the various activities undertaken by the assessee and eventually held as follows: "The fact that the product, which originally was a rough casting comes out as a new prod ..... X X X X Extracts X X X X X X X X Extracts X X X X
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