1997 (11) TMI 80

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....our opinion : "Whether, on the facts and circumstances of the case, the Tribunal was justified in holding that the assessee was entitled to investment allowance under s. 32A on the aircraft radio ?" The answer to this question revolves around the interpretation to be put to s. 32A of the IT Act, 1961, particularly, the expression "manufacture or production of any article or thing" as occurri....

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....the IAC. The Tribunal, in appeal, however, reversed the aforesaid finding and allowed the relief in favour of the assessee by holding that the activity of the assessee was such that it would fall within the purview of the expressions "manufacture" or "production" and that the ultimate photographs which came to be produced as a result of the business activity of the assessee came within the express....