https://www.taxtmi.com/caselaws?id=8650 Section 15C exempted profits of a qualifying industrial undertaking but denied relief where the undertaking was formed by splitting up or reconstruction of an existing business. The Calcutta HC noted that the Belur, Alupuram and Muri units involved substantial new buildings, machinery, capital expenditure and increased production, and were not shown to be mere feeders or replacements for parts earlier procured from outside. It held that reconstruction does not cover every expansion or extension; whether a new unit is formed by reconstruction depends on the nature and character of the undertaking and the facts of each case. The earlier textile machinery decision was distinguished on its facts, and the assessee was entitled to relief. en-us Thu, 09 Mar 1972 00:00:00 +0530 Sat, 09 May 2009 19:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8650 Section 15C exempted profits of a qualifying industrial undertaking but denied relief where the undertaking was formed by splitting up or reconstruction of an existing business. The Calcutta HC noted that the Belur, Alupuram and Muri units involved substantial new buildings, machinery, capital expenditure and increased production, and were not shown to be mere feeders or replacements for parts earlier procured from outside. It held that reconstruction does not cover every expansion or extension; whether a new unit is formed by reconstruction depends on the nature and character of the undertaking and the facts of each case. The earlier textile machinery decision was distinguished on its facts, and the assessee was entitled to relief. Case-Laws Income Tax Thu, 09 Mar 1972 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8650