Section 15C relief upheld for new and expanded industrial units that materially increased production output.

Section 15C of the Indian Income-tax Act, 1922 was treated as applicable to a new production centre and substantial extensions to existing manufacturing units where the additions in buildings, plant and machinery increased total output. Following the principle already applied in the connected Textile Machinery matter, the Court held that materially expanded industrial facilities could qualify for relief. The assessee was therefore entitled to section 15C relief, and the claim was upheld.

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Issues: Whether section 15C of the Indian Income-tax Act, 1922 applied to new production units and extensions added to existing manufacturing centres, so as to entitle the assessee to exemption.

Analysis: The appeal turned on the same principle already decided in the connected Textile Machinery matter. The assessee had established a new centre and made substantial additions to existing factories, including buildings, plant and machinery, resulting in an increased total output. On that basis, the earlier ruling allowing relief under section 15C was treated as governing the present case.

Conclusion: The assessee was held entitled to relief under section 15C of the Indian Income-tax Act, 1922, and the applicability of that provision to the new and expanded production units was answered in favour of the assessee.

Final Conclusion: The appeal failed and the assessee's claim for section 15C relief stood upheld.

Ratio Decidendi: Substantial new production facilities or materially expanded industrial units that add to output may qualify for relief under section 15C of the Indian Income-tax Act, 1922.

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