1986 (7) TMI 140

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....bsp;                           These appeals reiterate the claim for investment allowance under s. 32A and the relief under s. 80J. The assessee is a firm running a hotel with boarding and lodging facilities and a restaurant. The case of the assessee is that the prod....

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....sary that there should be a manufacture or processing of goods and even if there was only a production of an article, the assessee is entitled to the benefit. The cases cited by the Revenue state that the hotels providing food articles cannot be considered to be engaged in manufacturing activity. But, it cannot denied that they are engaged in the production of an article since be they are in the b....

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.... of the assessee that under sub-s. (6A), specific provision has been made for an audited account in respect of an assessee other than a company, and this indicated that the assessee would be entitled to the benefit under sub-s. (4) even if it does not fall under sub-s. (6). We are unable to agree. Even if the assessee is producing an article and may fall under sub-s. (4), generally the special pro....