https://www.taxtmi.com/caselaws?id=787090 Whether an industrial unit qualifies for deduction under Section 80-IC turned on whether its activities amounted to 'manufacture' or 'production' and whether the unit resulted from splitting-up/reconstruction. The unit's processing, calibration, assembly and testing produced a commercially distinct integrated engine cooling module with substantial value addition and multiple technical stages, satisfying 'manufacture/production' under Section 80-IC(2)(a); inter-unit transfers showed no pricing infirmity. Evidence of increased capacity and continued output established expansion rather than splitting-up, so Section 80-IC(4)(i) was not breached. Consequence: the unit met conditions for the Section 80-IC deduction and disallowances were deleted. en-us Wed, 18 Feb 2026 00:00:00 +0530 Thu, 26 Feb 2026 07:35:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787090 Whether an industrial unit qualifies for deduction under Section 80-IC turned on whether its activities amounted to 'manufacture' or 'production' and whether the unit resulted from splitting-up/reconstruction. The unit's processing, calibration, assembly and testing produced a commercially distinct integrated engine cooling module with substantial value addition and multiple technical stages, satisfying 'manufacture/production' under Section 80-IC(2)(a); inter-unit transfers showed no pricing infirmity. Evidence of increased capacity and continued output established expansion rather than splitting-up, so Section 80-IC(4)(i) was not breached. Consequence: the unit met conditions for the Section 80-IC deduction and disallowances were deleted. Case-Laws Income Tax Wed, 18 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787090