https://www.taxtmi.com/caselaws?id=26733 For investment allowance under section 32A, manufacture or production requires the undertaking to bring into existence a new and distinct marketable commercial commodity. A cold storage plant merely preserves goods and does not transform them into a new article or produce a marketable product, so its operation does not qualify as manufacture or production. The definition of "manufacturing process" in the Factories Act, 1948 cannot be imported into the Income-tax Act for this purpose because the two enactments serve different contexts. The treatment of cold storage separately in section 80J also supports that distinction, so the claim for investment allowance is not admissible. en-us Tue, 07 Jan 1986 00:00:00 +0530 Mon, 08 Feb 2010 12:06:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=26733 For investment allowance under section 32A, manufacture or production requires the undertaking to bring into existence a new and distinct marketable commercial commodity. A cold storage plant merely preserves goods and does not transform them into a new article or produce a marketable product, so its operation does not qualify as manufacture or production. The definition of "manufacturing process" in the Factories Act, 1948 cannot be imported into the Income-tax Act for this purpose because the two enactments serve different contexts. The treatment of cold storage separately in section 80J also supports that distinction, so the claim for investment allowance is not admissible. Case-Laws Income Tax Tue, 07 Jan 1986 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=26733