Data processing qualifies as industrial activity for investment allowance and deductions under Income-tax Act.

The High Court of Madhya Pradesh held that data processing qualifies as an industrial activity, entitling the assessee to both investment allowance and deductions under section 80J of the Income-tax Act, 1961. The court also ruled that computer machines used for data processing are entitled to investment allowance, aligning with decisions of the Commissioner and Tribunal. Consequently, the court decided in favor of the assessee on both issues, rejecting the Department's arguments and disposing of the case without costs.

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Issues involved:
The High Court of Madhya Pradesh was presented with questions regarding the eligibility of a business for deductions under section 80J and investment allowance for computer machines.

Deduction under section 80J:
The Tribunal referred questions to the court concerning the eligibility of the business of data processing with computers as an industrial undertaking for deduction under section 80J of the Income-tax Act, 1961. The assessee, a registered firm engaged in data processing, had claimed investment allowance on computers and deduction under section 80J for the assessment year 1982-83. The assessing authority initially disallowed the claims, but the Commissioner of Income-tax (Appeals) allowed them. The Tribunal also upheld the decision of the Commissioner, supported by a government decision recognizing data processing as an industrial activity. The court affirmed the view that data processing qualifies as an industrial activity, upholding the entitlement of the assessee to both investment allowance and deductions under section 80J.

Investment allowance for computer machines:
Another question referred to the court was whether computer machines used for data processing constitute office appliances and are entitled to investment allowance. The Commissioner and the Tribunal had both ruled in favor of the assessee, allowing the investment allowance on the computers. The court concurred with this view, citing the decision of the Gujarat High Court and finding no substantial reason to deviate from the concurrent opinion. Consequently, the court answered both questions in favor of the assessee and against the Department, disposing of the case without costs and fixing the counsel's fee.

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