Tyre-cord as automobile ancillary sustained on evidence, preserving entitlement to higher development rebate.

Tyre-cord manufactured by the assessee was treated by the Tribunal, on commercial evidence, as an automobile ancillary, and that view was not shown to be perverse or unsupported. The prior decision on the same issue for earlier assessment years, together with supporting Supreme Court authority, made a further reference unnecessary. The assessee's claim to the higher development rebate under section 33(1)(b)(B)(i) of the Income-tax Act, 1961, remained undisturbed.

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Issues: Whether the Tribunal was correct in holding that tyre-cord manufactured by the assessee was an automobile ancillary and whether the assessee was entitled to higher development rebate under section 33(1)(b)(B)(i) of the Income-tax Act, 1961.

Analysis: The Tribunal had taken a view on the evidence that, in a commercial sense, tyre-cord manufactured by the assessee was to be regarded as an automobile ancillary. That conclusion was not shown to be without evidence or perverse. In view of the earlier decision on the same question for preceding assessment years and the supporting Supreme Court authority, no useful purpose would be served by directing a reference.

Conclusion: The question was not fit for reference and the assessee's entitlement to the higher development rebate was not disturbed.

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