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| The Tax Publishers2019 TaxPub(DT) 6120 (Ranchi-Trib) INCOME TAX ACT, 1961
Section 80-IB(11A)
Where assessee's activity of dehusking of paddy into rice would amount to “manufacture or productionâ€, the assessee would be entitled for claim of deduction under section 80-IB(11A).
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Deduction under section 80-IB(11A) - Allowability - Assessee engaged in activity of dehusking of paddy into rice -
Assessee-company was running a rice-mill. AO took the view that the assessee was not eligible for deduction under section 80-IB(11A) as it was not engaged in business of integrated bulk handling storage and transportation of food grains and in fact, it was engaged in activity of dehusking of paddy into rice, which was not qualified for deduction under section 80-IB(11A). Held: There was no reason to hold that the activity of dehusking of paddy into rice would not amount to “manufacture or production” and there was no justification to give a narrower meaning to such terms, therefore, the assessee would be entitled for claim of deduction under section 80-IB(11A).
Relied:M/s Muthuramalingam Modern Rice Mill (Tax Case Appeal Nos.51 to 55 of 2009, judgment dated 20-2-2019]: 2019 TaxPub(DT) 2400 (Mad-HC)
REFERRED :
FAVOUR : In assessee's favour.
A.Y. :
INCOME TAX ACT, 1961
Section 263
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