https://www.taxtmi.com/caselaws?id=14078 Ship-breaking of unserviceable vessels purchased through government agencies was examined to determine whether it constitutes "manufacture or production" for deductions under ss. 80HHA and 80-I. Since "industrial undertaking" is undefined in the IT Act, it was construed liberally in a commercial sense; the activity qualified as an industrial undertaking, and commencement after the specified date was undisputed. Applying the SC test that manufacture/production requires transformation yielding commercially distinct movable articles, the HC held that ship-breaking results in new, independently saleable commercial commodities different from the original ship, including by-products and residual products. Consequently, the Tribunal's view was reversed, deductions under ss. 80HHA and 80-I were allowed, and the appeals were allowed in favour of the assessee. en-us Fri, 04 May 2001 00:00:00 +0530 Tue, 23 Dec 2025 15:30:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=14078 Ship-breaking of unserviceable vessels purchased through government agencies was examined to determine whether it constitutes "manufacture or production" for deductions under ss. 80HHA and 80-I. Since "industrial undertaking" is undefined in the IT Act, it was construed liberally in a commercial sense; the activity qualified as an industrial undertaking, and commencement after the specified date was undisputed. Applying the SC test that manufacture/production requires transformation yielding commercially distinct movable articles, the HC held that ship-breaking results in new, independently saleable commercial commodities different from the original ship, including by-products and residual products. Consequently, the Tribunal's view was reversed, deductions under ss. 80HHA and 80-I were allowed, and the appeals were allowed in favour of the assessee. Case-Laws Income Tax Fri, 04 May 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=14078