1997 (11) TMI 92

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....ther, on the facts and in the circumstances 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 Inco....

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.... It is in this background that the aforesaid 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....