https://www.taxtmi.com/caselaws?id=5341 SC allowed the revenue's appeal, set aside the HC's judgment, and restored the Tribunal's view that the assessee's new industrial undertaking commenced manufacture when it began producing cellulose pulp in March 1961. SC held that the HC, acting in a purely advisory capacity under the reference jurisdiction, could not interfere with the Tribunal's factual finding absent perversity or lack of evidence. The industrial licence for manufacture of CMC was construed to include manufacture of cellulose pulp as an intermediate, marketable product, consistent with the company's objects clause. Accordingly, for purposes of s.84(7) of the Income-tax Act, the five-year relief period commenced from the assessment year relevant to that production year. en-us Wed, 04 Sep 1991 00:00:00 +0530 Mon, 08 Dec 2025 15:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5341 SC allowed the revenue's appeal, set aside the HC's judgment, and restored the Tribunal's view that the assessee's new industrial undertaking commenced manufacture when it began producing cellulose pulp in March 1961. SC held that the HC, acting in a purely advisory capacity under the reference jurisdiction, could not interfere with the Tribunal's factual finding absent perversity or lack of evidence. The industrial licence for manufacture of CMC was construed to include manufacture of cellulose pulp as an intermediate, marketable product, consistent with the company's objects clause. Accordingly, for purposes of s.84(7) of the Income-tax Act, the five-year relief period commenced from the assessment year relevant to that production year. Case-Laws Income Tax Wed, 04 Sep 1991 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5341