https://www.taxtmi.com/caselaws?id=385722 The dominant issue was whether profits from extraction of crude palm oil from oil palm fresh fruit bunches qualified for deduction under s. 80IB(11A) as business of processing, preservation and packaging of "fruits." Interpreting s. 80IB(11A) purposively to promote agro-processing, the ITAT held oil palm fresh fruit bunches are "fruits" notwithstanding non-edibility in raw form, since the processed output is consumable. Relying on AAR authority, it held extraction of oil constitutes "processing," preservation is met by maintaining requisite standards/conditions to prevent deterioration, and storage in tanks/containers amounts to "packaging," which is not confined to retail packs. It further held the end product need not remain in the same form as the raw material. Deduction was allowed and the appeals succeeded. en-us Fri, 14 Jun 2019 00:00:00 +0530 Mon, 05 Jan 2026 12:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=385722 The dominant issue was whether profits from extraction of crude palm oil from oil palm fresh fruit bunches qualified for deduction under s. 80IB(11A) as business of processing, preservation and packaging of "fruits." Interpreting s. 80IB(11A) purposively to promote agro-processing, the ITAT held oil palm fresh fruit bunches are "fruits" notwithstanding non-edibility in raw form, since the processed output is consumable. Relying on AAR authority, it held extraction of oil constitutes "processing," preservation is met by maintaining requisite standards/conditions to prevent deterioration, and storage in tanks/containers amounts to "packaging," which is not confined to retail packs. It further held the end product need not remain in the same form as the raw material. Deduction was allowed and the appeals succeeded. Case-Laws Income Tax Fri, 14 Jun 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=385722