local authority could have assumed that
the legislative amendment would structurally change the provision of
Section 80IB(10) of the Act and it would
ignoring the fact that
the expenditure has neither resulted in any structural change to the
building nor in the creation of new capital asset ... existing building has not been altered
and there is no change to its structure as a result of the expenditure
incurred by the assessee
below:
(29BA) "manufacture", with its grammatical variations, means
a change in a non-living physical object or article or thing,--
(a) resulting ... object or
article or thing with a different chemical composition or integral
structure;]
7 I.T.A. Nos. 1326 & 1327/Mds/2012
Tamilnadu Cricket Association, ... vs Assessee on 23 January, 2013
IN THE INCOME TAX APPELLATE TRIBUNAL
Sengamala Thayar Educational Trust, ... vs Assessee on 7 March, 2013
IN THE INCOME TAX APPELLATE
Redington (India) Limited, Chennai vs Assessee on 4 April, 2013
IN THE INCOME TAX APPELLATE
Nippo Batteries Company Limited, ... vs Assessee on 10 January, 2013
IN THE INCOME TAX APPELLATE
what he makes profit of by parting
with it and letting it change masters."
Now so long as the expenditure in question ... capital of the assessee. The permanent
10 ITA No.107/Mds/2012
structure of which the income is to be the produce or fruit remain
Assessing Officer. As
per the assessee, the reopening was simply on a change of opinion.
On merits, for all the years, it was argued ... flavour and assessee has to be considered
as deemed owner of the structure. As for the reliance placed by the
assessee on the decision