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Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
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<h1>Labour contractor denied investment allowance under Income Tax Act</h1> The SC allowed the civil appeal filed by the Department for Assessment Year 1987-1988 regarding investment allowance under Section 32A(2)(b) of the Income ... Investment allowance under Section 32A(2)(b) - business of mining - labour contractor versus mining activity - concurrent findings of fact - appellate tribunal's confirmation of assessing officer's findingsInvestment allowance under Section 32A(2)(b) - business of mining - labour contractor versus mining activity - concurrent findings of fact - Assessee's entitlement to investment allowance for Assessment Year 1987-1988 - HELD THAT: - The Assessing Officer found that the assessee was not carrying on the business of mining but was engaged only in removal of overburden/earth excavation as a labour contractor for lignite project sites at Rajpardi and Pandhro. The Income Tax Appellate Tribunal upheld these findings of fact. The High Court's impugned judgment did not discuss or overturn those findings. On that basis the Court concluded that the assessee was not entitled to the investment allowance claimed under Section 32A(2)(b) for the year in question, and allowed the revenue's appeal.Appeal allowed; assessee not entitled to investment allowance for Assessment Year 1987-1988 as activities were of a labour contractor and not mining.Final Conclusion: The revenue's civil appeal is allowed; the Tribunal's and Assessing Officer's factual conclusion that the assessee was a labour contractor performing overburden removal (and not engaged in the business of mining) was upheld, resulting in denial of investment allowance for Assessment Year 1987-1988. The Supreme Court allowed the civil appeal filed by the Department for Assessment Year 1987-1988 regarding investment allowance under Section 32A(2)(b) of the Income Tax Act, 1961. The court found that the assessee was not entitled to the allowance as they were deemed to be a labour contractor. The appeal was allowed with no costs.
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