1994 (1) TMI 63

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....appeal, the following questions have been referred : "(i) Whether the borrowed capital could be treated as part of capital for purposes of working out relief under section 80J notwithstanding the provisions of rule 19A(3) of the Income-tax Rules, 1962, in the facts and circumstances of the case ? (ii) Whether, on the facts and circumstances of the case, the assessee-company could be treated ....

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.... the assessee is engaged in the manufacture or processing of goods. The Appellate Tribunal found that the assessee is engaged in processing prawns, cutting and packing them in cartons, to be made ready for shipping. Moreover, in the assessment itself, relief under section 80J of the Income-tax Act has been granted, treating the undertaking of the assessee as an industrial undertaking, which also r....