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    <title>1997 (6) TMI 365 - ITAT MUMBAI</title>
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    <description>Shipbreaking was held not to constitute manufacture or production for deductions under sections 80HH, 80HHA and 80-I because the statutory test requires a process that creates a new and commercially distinct article with a different name, character or use. Dismantling a ship purchased as scrap and segregating recovered materials for sale did not meet that standard, so the deductions were denied. The additional tax under section 104 was also held leviable because the cancellation of that levy depended only on the rejected premise that the assessee was engaged in manufacturing; once that premise failed, the levy was restored.</description>
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    <pubDate>Fri, 20 Jun 1997 00:00:00 +0530</pubDate>
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      <title>1997 (6) TMI 365 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=281562</link>
      <description>Shipbreaking was held not to constitute manufacture or production for deductions under sections 80HH, 80HHA and 80-I because the statutory test requires a process that creates a new and commercially distinct article with a different name, character or use. Dismantling a ship purchased as scrap and segregating recovered materials for sale did not meet that standard, so the deductions were denied. The additional tax under section 104 was also held leviable because the cancellation of that levy depended only on the rejected premise that the assessee was engaged in manufacturing; once that premise failed, the levy was restored.</description>
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      <pubDate>Fri, 20 Jun 1997 00:00:00 +0530</pubDate>
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