Industrial undertaking status for garment manufacturing upheld, allowing section 80J deduction for the assessee.

A manufacturing unit engaged in producing and exporting garments was treated as an industrial undertaking within the statutory understanding applied for section 80J relief. The Court followed its earlier view that such manufacturing activity satisfies the requirement for deduction, and held that the assessee qualified for the statutory benefit. The reference was answered in favour of the assessee and against the Revenue, and the deduction claim was upheld.

---

---

Issues: Whether the assessee's manufacturing unit constituted an industrial undertaking for the purposes of deduction under section 80J of the Income-tax Act, 1961.

Analysis: The question was examined in the context of the assessee's activity of manufacturing and exporting garments. The Court followed its earlier view that such manufacturing activity falls within the relevant statutory concept of an industrial undertaking, and treated the activity as satisfying the requirement for section 80J relief.

Conclusion: The assessee was held to be an industrial undertaking and was entitled to deduction under section 80J. The question referred was answered in the affirmative, in favour of the assessee and against the Revenue.

Final Conclusion: The reference was answered for the assessee, and the claim to the statutory deduction was upheld.

Ratio Decidendi: A manufacturing unit engaged in production of garments can constitute an industrial undertaking for the purpose of section 80J where the activity falls within the statutory understanding applied by the Court.

---