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Dispute concerned entitlement to deduction under Section 80IC for an Uttarakhand unit: tribunal held the unit's conversion of electrical steel into graded laminations and assembly of an integrated cooling module amounted to 'manufacture' because a commercially distinct commodity with distinct end-use emerged, applying the distinct-commodity test. Prior precedents on transformation and design supported manufacture. The tribunal found no evidence that the unit was formed by splitting-up or reconstruction of existing business and inter-unit transfers were at arm's length; consequently the unit met the conditions of Section 80IC(2)(a) and was not barred by Section 80IC(4)(i), and the assessing officer's disallowance was deleted.
Dispute concerned entitlement to deduction under Section 80IC for an Uttarakhand unit: tribunal held the unit's conversion of electrical steel into graded laminations and assembly of an integrated cooling module amounted to 'manufacture' because a commercially distinct commodity with distinct end-use emerged, applying the distinct-commodity test. Prior precedents on transformation and design supported manufacture. The tribunal found no evidence that the unit was formed by splitting-up or reconstruction of existing business and inter-unit transfers were at arm's length; consequently the unit met the conditions of Section 80IC(2)(a) and was not barred by Section 80IC(4)(i), and the assessing officer's disallowance was deleted.
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