Investment allowance under section 32A denied where earlier rulings on identical facts controlled the assessee's claim

Investment allowance under section 32A was held unavailable for machinery installed in the relevant accounting year because the Madras HC followed its earlier rulings on the same issue, including the assessee's own case. Applying the same reasoning to the assessment year 1982-83, the Court upheld the Tribunal's view that the assessee was not entitled to the allowance. The question referred was answered in the affirmative and against the assessee, reflecting that prior decisions on identical facts controlled the outcome.

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Issues: Whether the assessee was entitled to investment allowance under section 32A of the Income-tax Act in respect of machinery installed in the accounting year.

Analysis: The Court followed its earlier decisions on the same issue and in the assessee's own case, and applied the same reasoning to the present reference for the assessment year 1982-83. On that basis, the Tribunal's view that the assessee was not entitled to the allowance was upheld.

Conclusion: The assessee was not entitled to investment allowance under section 32A of the Income-tax Act, and the question referred was answered in the affirmative and against the assessee.

Ratio Decidendi: Where the controlling earlier on identical facts holds the field, investment allowance under section 32A is unavailable to the assessee for machinery installed in the accounting year.

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