2001 (4) TMI 10

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.... the assessment years 1980-81 to 1984-85 were referred for the opinion of the High Court under section 256(2) of the Income-tax Act, 1961: "(1) Whether, on the facts and in the circumstances of the case, the Tribunal is right in law and fact in holding that the assessee is an industrial company eligible to be taxed only at the rate of 55 per cent? (1)(a) Whether processing of marine products....

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....in favour of the assessee, has relied upon the decisions of the Kerala High Court in CIT v. Marwell Sea Foods [1987] 166 ITR 624 and CIT v. Relish Foods [1989] 180 ITR 454. The case of the assessee for claiming allowance under section 80HH is that it is an industrial undertaking that manufactures/produces articles. The Tribunal has held that the activities of the assessee involve purchasing, pe....