Court upholds deduction for job work income under Income-tax Act, emphasizing on specified businesses.

Commissioner of Income-tax Versus Impel Forge and Allied Industries Limited

Commissioner of Income-tax Versus Impel Forge and Allied Industries Limited - [2010] 326 ITR 27 (P&H) Issues:
Interpretation of deduction under section 80-IB of the Income-tax Act for income derived from job work.

Analysis:
The judgment delivered by the High Court pertains to an appeal under section 260A of the Income-tax Act, 1961 against the order of the Income-tax Appellate Tribunal. The main issue raised was whether deduction under section 80-IB is permissible on income derived from processing activities as processing activities do not constitute the manufacture of a product. The assessee, engaged in manufacturing and trading of tractor and auto parts, claimed deduction under section 80-IB on income from job work, which was partly allowed by the Assessing Officer. The Commissioner of Income-tax (Appeals) upheld the plea of the assessee, a decision affirmed by the Tribunal.

The Revenue contended that the deduction under section 80-IB was not admissible for the job works done for others. However, the court pointed out that the applicability of section 80-IB only requires deriving income from businesses specified in the Act, without any distinction between manufacturing for self or others. The Tribunal's decision was supported by the Delhi High Court's similar view in a previous case.

The court held that since the Tribunal's decision aligns with the statutory language, no substantial question of law arises. Consequently, the appeal was dismissed, affirming the Tribunal's decision on the deduction under section 80-IB for income derived from job work.