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1 - 10 of 12 (0.02 seconds)The Income Tax Act, 1961
Section 80HH in The Income Tax Act, 1961 [Entire Act]
The Finance Act, 2018
Section 32A in The Income Tax Act, 1961 [Entire Act]
Section 33 in The Income Tax Act, 1961 [Entire Act]
The Industrial Disputes Act, 1947
Commissioner Of Income-Tax, Bombay ... vs Pressure Pilling Co. (India) P. Ltd. on 10 January, 1979
According to him, the Bombay High Court decision in the case of Pressure Piling (supra) is directly applicable on the point at issue since that was also a case of a construction company and the claim was regarding deduction under Section 80J. Reliance had been placed on the Orissa High Court decision to show that a construction activity is also an industrial activity. It has been submitted, on a factual plan, that in building construction work, the land is excavated at several places for laying the foundation on which the entire superstructure is erected. Wherever necessary, piles are laid for the foundation. The raising of columns, construction of walls, laying of roof, flooring, installation of sanitary system, laying of cables, fixing of doors and windows are the main requirements for the erection of a building. It was further submitted that at every stage some or other engineering process is involved and some kind of manufacture of one or the other article is produced. The components mainly used in the construction of buildings are cement, steel, sand, timber, etc. Several articles are processed or manufactured in the course of erection of a building. The finished product, which is distinct and different in shape from the raw materials used, cannot be anything but an article. Relying on the decision of the Orissa High Court, it is submitted that if a dam is an article, a building would certainly be considered as an article.
Section 2 in The Finance Act, 1996 [Entire Act]
Commissioner Of Income-Tax vs N.C. Budharaja And Company on 13 November, 1979
14. The Orissa High Court decision is certainly an authority to say what is an industrial undertaking under Section 80HH ? But, we cannot accept the extension sought to be placed by including construction of building as manufacture. What constituted manufacture in that case has been specifically emphasised by us in the passage quoted above. The italicized portion would show that the High Court was satisfied that in construction of a dam, some parts which are manufactured by the assessee were used. The High Court has not, we must point out, found the whole contention to be a manufacturing activity.