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Investment allowance u/s 32AC - claim disallowed as assessee do not fulfill the requisite condition - The ITAT sided with the assessee, affirming that the activities of blending lubricant oil qualified as "manufacture" or "production", thus making them eligible for investment allowance under Section 32AC. The Tribunal found the Revenue's interpretation of the term "manufacture" too narrow and not in line with the legislative intent or judicial precedents that recognize a broader understanding of "production".
Investment allowance u/s 32AC - claim disallowed as assessee do not fulfill the requisite condition - The ITAT sided with the assessee, affirming that the activities of blending lubricant oil qualified as "manufacture" or "production", thus making them eligible for investment allowance under Section 32AC. The Tribunal found the Revenue's interpretation of the term "manufacture" too narrow and not in line with the legislative intent or judicial precedents that recognize a broader understanding of "production".
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