Industrial undertaking test for chicory processing denied tax deductions for simple roasting and powdering activity

Roasting chicory roots and then powdering them was treated as insufficient to satisfy the test for an industrial undertaking applied in the controlling precedent. On that basis, the assessee-firm was held not entitled to deductions under sections 80HH, 80-I and 80J of the Income-tax Act, 1961.

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Issues: Whether the assessee-firm was an industrial undertaking eligible for deduction under sections 80HH, 80-I and 80J of the Income-tax Act, 1961.

Analysis: The only process shown on record for making chicory powder was roasting the roots and then powdering them. On that material, the activity did not satisfy the test governing an industrial undertaking as laid down in the controlling precedent relied upon by the Court.

Conclusion: The assessee-firm was not entitled to deduction under sections 80HH, 80-I and 80J.

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