Xerox duplication is not manufacture for investment allowance, so the xerox machine did not qualify under section 32A.

Under section 32A of the Income-tax Act, mere duplication of documents with a xerox machine is not manufacture of goods, articles or things. The process produces only a copy of the original document, in substance similar to carbon duplication, and does not transform the activity into manufacturing. On that basis, investment allowance was not available in respect of the xerox machine, and the issue was decided in favour of the Revenue and against the assessee.

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Issues: Whether the assessee, engaged in making xerox copies of documents with the aid of a xerox machine, was entitled to investment allowance under section 32A of the Income-tax Act, 1961 in respect of the xerox machine.

Analysis: The assessment year being 1984-85, the claim fell to be examined under section 32A. The activity undertaken with the xerox machine was held to be merely duplication of documents and not a process resulting in the manufacture of any goods, articles or things. The end product was only a copy of the original document, similar in substance to carbon duplication, and the use of the machine did not convert the activity into manufacture.

Conclusion: The assessee was not entitled to investment allowance under section 32A in respect of the xerox machine, and the question was answered in favour of the Revenue and against the assessee.

Ratio Decidendi: Mere duplication of documents with a xerox machine does not amount to manufacture of goods, articles or things for the purpose of investment allowance.

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