Prawn processing as production of articles qualifies as an industrial undertaking for section 80J relief on binding precedent.

Processing prawns was treated as production of articles, so the activity qualified as an industrial undertaking for relief under section 80J of the Income-tax Act, 1961. The High Court followed its earlier binding view in the assessee's own case and the connected precedent on the same activity. On that basis, the assessee's entire business income was held eligible for section 80J relief, and the referred question was answered in favour of the assessee.

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Issues: Whether the assessee's business of processing prawns was an industrial undertaking eligible for relief under section 80J of the Income-tax Act, 1961, for the entire business income.

Analysis: The issue was answered by applying the earlier binding view that processing of prawns amounts to production of articles. On that reasoning, such processing activity qualifies as an industrial undertaking for the purposes of section 80J. The court followed the prior decision in the assessee's own case and the connected precedent on the same activity.

Conclusion: The assessee's entire business was held eligible for relief under section 80J, and the answer to the referred question was given in favour of the assessee and against the Revenue.

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