https://www.taxtmi.com/caselaws?id=21384 The court held that machinery in a cold storage facility did not qualify for investment allowance under Section 32A(2)(b)(iii) of the Income-tax Act as cold storage operations did not amount to "manufacture" or "production" of a new article. Relying on various High Court decisions, the court concluded that the primary purpose of a cold storage is preservation, not transformation, thus denying the investment allowance claim. The decision favored the Revenue, rejecting the assessee's claim and awarding costs of Rs. 500. en-us Thu, 24 Oct 1991 00:00:00 +0530 Tue, 24 Nov 2009 10:35:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=21384 The court held that machinery in a cold storage facility did not qualify for investment allowance under Section 32A(2)(b)(iii) of the Income-tax Act as cold storage operations did not amount to "manufacture" or "production" of a new article. Relying on various High Court decisions, the court concluded that the primary purpose of a cold storage is preservation, not transformation, thus denying the investment allowance claim. The decision favored the Revenue, rejecting the assessee's claim and awarding costs of Rs. 500. Case-Laws Income Tax Thu, 24 Oct 1991 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=21384