1996 (4) TMI 64

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....-84 and 1984-85, for our consideration and opinion : " 1. Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was justified in law in holding that the assessee is an 'industrial undertaking' engaged in the manufacture or production of articles or things and thereby holding that it is entitled to deduction under sections 80HHA and 80J of the Income-tax Act, 1961 ? 2. Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was justified in holding that the assessee is entitled to investment allowance under section 32A and whether construction of buildings, dams, roads, etc., amounts to manufacture or production of articles or things as envisaged under sectio....

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....he applicant, and Shri Nazir Singh, learned counsel for the non-applicant. Section 80HHA of the Act permits deduction in respect of profits and gains from newly established small scale industrial undertakings in certain areas. Section 80J of the Act permits deduction in respect of profits and gains from newly established industrial undertakings or ships or hotel business in certain cases. Section 32A of the Act deals with investment allowance. Section 32A(2)(b)(iii) provides as under : (iii) in any other industrial undertaking for the purposes of business of construction, manufacture or production of any article or thing, not being an article or thing specified in the list in the Eleventh Schedule." Counsel for the non-applicant ve....