Poultry dressing was not treated as manufacture, so deduction claims for an industrial undertaking failed.

An assessee engaged in poultry rearing and dressing poultry for sale was held not entitled to deductions under Section 80-I or Section 80HH of the Income-tax Act, 1961. The Court applied its earlier decision against the assessee and rejected the claim that dressing poultry for sale amounted to manufacture, because no material was placed before the Tribunal to establish that the activity was manufacturing in nature. On that basis, the activity was not treated as an industrial undertaking, and the denial of deduction was upheld.

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Issues: Whether the assessee, engaged in poultry rearing and dressing of poultry for sale, was entitled to deduction under Section 80-I and Section 80HH of the Income-tax Act, 1961 on the footing that its activity amounted to manufacture or that it was an industrial undertaking.

Analysis: The Court noted that the controversy was covered against the assessee by its earlier decision. The assessee's additional contention that dressing the poultry for sale amounted to manufacture could not be accepted because no material had been placed before the Tribunal to establish that such activity constituted manufacture. In the absence of supporting material, the activity could not be treated as manufacturing activity for the purpose of the deductions claimed.

Conclusion: The assessee was not entitled to deduction under Section 80-I or Section 80HH of the Income-tax Act, 1961, and the finding that it was not an industrial undertaking was upheld.

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