1997 (11) TMI 92

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....nces of the case, the Tribunal was justified in holding that the assessee manufactured and produced "articles" within the meaning of section 80J(4)(iv) (now section 80-I(2)(iv) of the Act) of the Income-tax Act, 1961, and thereby directing the Assessing Officer to allow deduction under section 80-I of the said Act in the assessment year 1983-84 ?" The Income-tax Officer disallowed the claim of th....

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....aid question has been referred for our opinion. In the case of CIT v. N. C. Budharaja and Co. [1993] 204 ITR 412, the Supreme Court while interpreting analogous provisions contained in section 80HH of the Income-tax Act dealing with the expression "industrial undertaking" has clearly held that constructing a dam is not process of manufacture or a process of production. The dam is constructed, it ....