Mere relocation of an industrial unit does not amount to factory expansion and cannot justify cancellation of tax eligibility benefits.

Mere shifting of an industrial unit from one location to another does not amount to addition or extension of an existing factory unless there is material showing increased production capacity or other factual basis for expansion. On the record, the unit had only changed location and directors, with no evidence of capacity enhancement, so the cancellation of the eligibility certificate was not justified. The Tribunal's view that relocation alone is insufficient to treat the unit as an expanded factory was held sustainable.

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Issues: Whether mere shifting of the industrial unit from one place to another amounted to addition or extension of an existing factory so as to justify cancellation of the eligibility certificate.

Analysis: The record showed that the unit had shifted location and the Directors had been replaced, but there was no material showing any increase in production capacity or any factual basis to treat the change as an addition or extension of an existing factory. The earlier view that mere shifting of a unit does not amount to addition or extension was followed, and the Tribunal's reasoning was found to be sustainable.

Conclusion: Mere shifting of the unit did not amount to addition or extension of an existing factory, and the cancellation of the eligibility certificate was not justified.

Ratio Decidendi: Mere relocation of a unit, any increase in production capacity or other material showing expansion of the existing factory, does not constitute addition or extension for the purpose of denying tax eligibility benefits.

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