Investment allowance for marble mining treated as production under section 32A, enabling eligibility for tax relief.

Investment allowance under section 32A of the Income-tax Act was considered in the context of an assessee engaged in mining and extraction of marble. The analysis states that the allowance is available to an industrial undertaking carrying on business of construction, manufacture or production of an article or thing specified in the Eleventh Schedule, and that marble is included in that Schedule. Even if mining of marble does not amount to manufacture, it constitutes production for section 32A(2)(b)(iii). On that basis, the assessee was held entitled to investment allowance, with the reference answered against the Revenue.

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Issues: Whether an assessee engaged in mining and extraction of marble is entitled to investment allowance under section 32A of the Income-tax Act, 1961.

Analysis: Investment allowance under section 32A is available to an industrial undertaking carrying on business of construction, manufacture or production of an article or thing specified in the Eleventh Schedule. Marble is included in the Eleventh Schedule. Even if mining of marble may not amount to manufacture, section 32A(2)(b)(iii) applies where the undertaking carries on the business of production. Mining of marble constitutes production for this purpose.

Conclusion: The assessee is entitled to investment allowance under section 32A of the Income-tax Act, 1961, and the question referred was answered against the Revenue.

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