https://www.taxtmi.com/caselaws?id=24083 Income is attributable to manufacturing activity under section 2(6)(c) of the Finance Act, 1970 only if it has a sufficiently proximate and direct nexus with the relevant unit. Profit on sale of chemicals was treated as trading income, and the nomination premium from transfer of export incentive licence was held to arise from export activity rather than manufacture or processing of leather. Interest allocation to the tannery division was accepted as apportionable against manufacturing profits, but the disputed receipts were not. The assessee therefore failed the 51% test and was not an industrial company; the reference was answered against it. en-us Fri, 03 Feb 1989 00:00:00 +0530 Sat, 16 Jan 2010 15:25:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=24083 Income is attributable to manufacturing activity under section 2(6)(c) of the Finance Act, 1970 only if it has a sufficiently proximate and direct nexus with the relevant unit. Profit on sale of chemicals was treated as trading income, and the nomination premium from transfer of export incentive licence was held to arise from export activity rather than manufacture or processing of leather. Interest allocation to the tannery division was accepted as apportionable against manufacturing profits, but the disputed receipts were not. The assessee therefore failed the 51% test and was not an industrial company; the reference was answered against it. Case-Laws Income Tax Fri, 03 Feb 1989 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=24083