Calcined petroleum coke is not mineral oil under income tax law; revisionary order under challenge was quashed.

Calcined petroleum coke was held not to be "mineral oil" for the purposes of Section 80HHC(2)(b) of the Income-tax Act, following an earlier binding decision on the same question of law. On that basis, the Tribunal's view treating it as mineral oil was found incorrect, and the revisionary order under Section 263(1) could not be sustained. The question was answered in favour of the assessee and against the Revenue, and the orders of the Tribunal and the Commissioner were quashed.

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Issues: Whether calcined petroleum coke manufactured by the assessee was a "mineral oil" within the meaning of Section 80HHC(2)(b) of the Income-tax Act, 1961.

Analysis: The appeal was decided by following the earlier binding decision on the same question of law. On that basis, the Tribunal's view that calcined petroleum coke was a "mineral oil" was found to be incorrect, and the revisionary order under Section 263(1) of the Income-tax Act, 1961 could not be sustained.

Conclusion: The question was answered in favour of the assessee and against the Revenue. The orders of the Tribunal and the Commissioner were quashed and set aside.

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