Data processing as processing goods sustained industrial company status and investment allowance claim.

Processing of client data was treated as processing goods, which preserved the company's claim to industrial company status and investment allowance for the generator installed by it. The authorities below had accepted that characterisation, and the Supreme Court found no contrary judicial authority to dislodge it. It also declined to reappraise primary material not placed before the income-tax authorities or the Tribunal, leaving the factual finding undisturbed and rejecting the Revenue's challenge.

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Issues: Whether the respondent-company, in processing data on behalf of its clients, was processing goods so as to qualify for the benefit of an industrial company and investment allowance in respect of the generator installed by it.

Analysis: The authorities below had treated data processing as processing goods and on that basis extended the benefit claimed. The Revenue was unable to point to any contrary judicial authority. The Court declined to reappraise primary material not placed before the income-tax authorities or the Tribunal.

Conclusion: The finding that processing data amounted to processing goods was left undisturbed and the appeal failed.

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