Cold storage activity is not manufacture or production for investment allowance; preservation alone does not create a new marketable commodity.

For investment allowance under section 32A, manufacture or production requires the undertaking to bring into existence a new and distinct marketable commercial commodity. A cold storage plant merely preserves goods and does not transform them into a new article or produce a marketable product, so its operation does not qualify as manufacture or production. The definition of "manufacturing process" in the Factories Act, 1948 cannot be imported into the Income-tax Act for this purpose because the two enactments serve different contexts. The treatment of cold storage separately in section 80J also supports that distinction, so the claim for investment allowance is not admissible.

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Issues: Whether the operation of a cold storage plant amounts to "manufacture" or "production" of any article or thing for the purpose of investment allowance under section 32A of the Income-tax Act, 1961, and whether the definition of "manufacturing process" in the Factories Act, 1948 can be imported for that purpose.

Analysis: The expression "manufacture" and "production" was not defined in the Income-tax Act, 1961, so the words had to be understood in their ordinary and contextual sense. The meaning could not be borrowed from the Factories Act, 1948 because a definition in one enactment cannot automatically govern another. The relevant context of section 32A showed that the undertaking must bring into existence a new and distinct marketable commercial commodity. A cold storage plant merely preserves goods; it does not transform them into a new article or produce a marketable product. The reference to cold storage in section 80J of the Income-tax Act, 1961 also indicated that operation of a cold storage plant was treated separately from manufacture or production of articles.

Conclusion: The assessee's cold storage activity did not amount to manufacture or production, and the claim for investment allowance was not admissible. The definition in section 2(k) of the Factories Act, 1948 could not be imported into section 32A of the Income-tax Act, 1961.

Ratio Decidendi: For investment allowance under section 32A, manufacture or production must result in a new and distinct marketable commodity, and a cold storage operation that merely preserves goods does not satisfy that test.

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