Investment allowance for fish processing machinery denied under binding precedent on section 32A eligibility.

Investment allowance under section 32A was denied for plant and machinery used in fish processing because the issue had already been covered by binding precedent on the scope of allowance for processing activities. The High Court confined the question to the assessee's fish-processing operations and held that the Tribunal's view in favour of the assessee could not stand in light of the earlier Supreme Court ruling. The operative effect was that the assessee was not entitled to the allowance, and the matter was decided in favour of the Revenue.

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Issues: Whether the assessee was entitled to investment allowance under section 32A of the Income-tax Act, 1961 on plant and machinery used in its activity of processing fish.

Analysis: The Court reframed the question to confine it to the assessee's fish-processing activity. It noted that the issue had already been decided against the assessee in earlier binding decisions, including the Supreme Court's ruling on the scope of investment allowance under section 32A in relation to processing activities. In light of the governing precedent, the Tribunal's view favouring the assessee could not be sustained.

Conclusion: The assessee was not entitled to investment allowance under section 32A for the plant and machinery used in processing fish, and the answer was in favour of the Revenue.

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