TaxTMI 
TaxTMI 
1984 (11) TMI 88
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....21. In ground Nos. 11 to 13, the assessee has raised the question of allowance of investment allowance with regard to the generator installed by it in its hotel, which is for the purpose of air-conditioning the hotel. According to the assessee, it was engaged in a business of manufacturing or producing articles and, therefore, it was entitled to development allowance in terms of section 32A of the....
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....he assessee is merely a trading concern, and that making various dishes out of food articles did not amount to manufacture or production of an article and that air-conditioning the atmosphere did not mean either production or manufacture of the atmosphere, even though it may be possible to term the atmosphere as a ' thing '. In support of the above, reliance was placed by the learned departmental ....
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....he act of manufacturing such food stuff or producing a thing. The air-conditioning of the atmosphere in the hotel for the convenience of the customers also, in our opinion, does not amount to manufacturing or producing a thing, as claimed by the assessee. Reliance on the decision of the Hon'ble Punjab and Haryana High Court in the case of Jamuna Cold Storage and of that of the Hon'ble Allahabad Hi....