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15. We have heard counsel appearing for the assessee as well as the Revenue. It is an admitted fact that the instruments division of the Alfa Electro Unit was nothing but a small-scale unit. The instruments division was concerned with the manufacture of various kinds of voltmeters, oscilloscopes and calibrators. These are electronic testing and measuring instruments. This busines$ was different and distinct from the manufacture of mini-computers or micro processors. In fact, the Government of India through its letter dated September 18, 1979, clarified that an industrial licence will be necessary under the Industries (Development 'and Regulation) Act, 1951, for the establishment of a new industrial undertaking in the State of Haryana for the manufacture of mini-computers and micro processor-based systems subject to certain conditions to be fulfilled by the assessee. Admittedly, no licence had, so far, been received by the assessee-company for the manufacture of mini-computers and micro processor-based systems. The assessee-company did not produce any material before the Tribunal to show that the instruments division and the mini-computers division were part and parcel of the same business. No material to this effect were placed by the assessee-company either before the Income-tax Officer or before the Commissioner (Appeals). Even in this court, counsel for the assessee has not referred to any material to show that the instruments division and the mini-computer division were part and parcel of the same business.