CIT v. Oracle Software India Ltd.

CIT vs. Sadhu Forging Ltd

…ITR 98 (SC), the 11. conversion of jumbo rolls of photographic films into small flats and rolls in desired sizes amounts to manufacture or production eligible for deduction under Sections 80HH and 80I. In another case titled CIT v. Oracle Software India Ltd., 320 ITR 546 (SC), it was observed that if an operation/process renders commodity or article fit for use for which it was otherwise not fit, the operation/process falls within the meaning of the word "manufacture" – in the instant case, the assessee undertakes an operation which renders a blank CD fit for use for which it was otherwise not fit - by the duplic…

CIT vs. Sadhu Forging Ltd

…98 (SC), the conversion of jumbo rolls of photographic films into small flats and rolls in desired sizes amounts to manufacture or production eligible for deduction under Sections 80HH and 80I. In another case titled CIT v. Oracle Software India Ltd., 320 ITR 546 (SC), it was observed that if an operation/process renders commodity or article fit for use for which it was otherwise not fit, the operation/process falls within the meaning of the word “manufacture” – in the instant case, the assessee undertakes an operation which renders a blank CD fit for use for which it was otherwise not fit – by the…

Commissioner of Income Tax vs. M/S Hls India Ltd

The appeals are dismissed

Bench: Coming To These Legal Issues It Would Be Pertinent, In The Light Of Facts & Circumstances Of These Cases, First Of All To Succinctly Narrate The Genesis Of Instant Prolonged Tax Dispute Between The Revenue & The Assessee.

…. [201 ITR 17 (Cal) 5. Ship Scrap Traders Vs. CIT [251 ITR 806 (Bom)] 6. CIT Vs. Emirates Commercial Bank Ltd. [ 262 ITR 55 (Bom)] 7. CIT Vs. Professional Information Systems and Management. [274 ITR 242 (Guj)] 8. CIT Vs. Oracle Software India Ltd. [320 ITR 546 (SC)] ITA Nos. 194/2005, 208/2002 & Ors. Connected Matters Page 14 of 52 17. In the case of I.B.M. World Trade Corporation (supra) the question before the Bombay High Court was as to whether E.A. Machines (now called Data Processing Machines) were office appliances not eligible for allowance of development rebate…

Commissioner of Income Tax vs. Hls Asia Limited

The appeals are dismissed

Bench: HON'BLE MR. JUSTICE A.K.SIKRI,HON'BLE MR. JUSTICE M.L. MEHTA

…nd Co. Ltd. [201 ITR 17 (Cal) Ship Scrap Traders Vs. CIT [251 ~TR 806 (Born)] CIT Vs. Emirates Commercial Bank Ltd. [ 262 ITR 55 (Born)] CIT Vs. Professional Information Systems and Management. [274 ITR 242 (Guj)] CIT Vs. Oracle Software India Ltd. [320 ITR 546 (SC)] ITA Nos. 194/2005, 208/2002 & Ors. Connected Matters Page 13of52 Uf' --~.------ 17. In the case of l.B.M. World Trade Corporation (supra) the question before the Bombay High Court was as to whether E.A. Machines (now called Data Processing Machines) were office appliances not eligible for allowance of development rebate under sec…

Commissioner of Income Tax vs. M/S Hls India Ltd

The appeals are dismissed

Bench: Coming To These Legal Issues It Would Be Pertinent, In The Light Of Facts & Circumstances Of These Cases, First Of All To Succinctly Narrate The Genesis Of Instant Prolonged Tax Dispute Between The Revenue & The Assessee.

…. [201 ITR 17 (Cal) 5. Ship Scrap Traders Vs. CIT [251 ITR 806 (Bom)] 6. CIT Vs. Emirates Commercial Bank Ltd. [ 262 ITR 55 (Bom)] 7. CIT Vs. Professional Information Systems and Management. [274 ITR 242 (Guj)] 8. CIT Vs. Oracle Software India Ltd. [320 ITR 546 (SC)] 2011:DHC:2637-DB ITA Nos. 194/2005, 208/2002 & Ors. Connected Matters Page 14 of 52 17. In the case of I.B.M. World Trade Corporation (supra) the question before the Bombay High Court was as to whether E.A. Machines (now called Data Processing Machines) were office appliances not eligible for allowance of d…