2004 (4) TMI 19

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....amoorthy J.- The tax case appeals have been filed against the common order passed by the Income-tax Appellate Tribunal in I.T.A. Nos. 1189 and 1190 of 1992, pertaining to the assessment years 1987-88 and 1988-89. The appellant, viz., the Madurantakam Co-operative Sugar Mills Limited, Padalam, is engaged in the business of manufacture of sugar. While computing the total income for the assessment....

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....r 1984-85 only. The Commissioner also took the view that the deduction allowed under section 80P(2)(a)(i) and under section 80P(2)(a)(iii) was not in order as the assessee was a co-operative society engaged in the manufacture of sugar and not one engaged in the business of banking or providing credit facilities for its members. As the Commissioner of Income-tax felt that the assessments for both t....

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.... appeals. A reading of section 80J(2) of the Income-tax Act would show that the deduction specified in sub-section (1) shall be allowed in computing the total income in respect of the assessment year relevant to the previous year in which the industrial undertaking begins to manufacture or produce articles and each of the four assessment years immediately succeeding the initial assessment year.....