CIT v. Tamil Nadu Heat Treatment and Fetting Services (P) Ltd. (No. 1)

238 ITR 529High Court1999#8897 most cited

What is CIT v. Tamil Nadu Heat Treatment and Fetting Services (P) Ltd. (No. 1) authority for?

The process of heat treatment applied to automobile parts like crankshafts constitutes manufacturing and is eligible for deductions, as it renders the parts marketable by imparting essential qualities for their intended use, even without a physical change.

12

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2011 to 2013.

Also referred to as

CIT v. Tamil Nadu Heat Treatment and Fetting Services (P) Ltd. · manufacturing · heat treatment · crankshaft · automobile parts · marketable · deductions · qualitative change · Section 80I · business income

Issues it is cited on

section 32asection 80ibsection 260section 260asection 80igross total incomesection 26section 80indiabusinesscompanytotal income

Judgments citing CIT v. Tamil Nadu Heat Treatment and Fetting Services (P) Ltd. (No. 1)

Commissioner of Income Tax-IV vs. Delhi Press Patra Prakashan Ltd

ITA-480/2005HC Delhi31 May 2013
For Appellant: Mr N.P. SahniFor Respondent: Mr O.P. Dua, Sr. Adv. with Ms Babita
Section 143(1)Section 260ASection 80

…ughen them to the requisite standards, so that they could be sold in the market. The activity was held to be manufacturing and entitled to claim deductions. Similarly in the case of CIT v. Tamil Nadu Heat Treatment and Fetting Services (P) Ltd. (No. 1) [1999] 238 ITR 529 (Mad), it was held that the process of heat treatment to crankshaft, etc., were absolutely essential for rendering it marketable. Automobile parts, as crankshafts, need to be subjected to heat treatment to increase the wear and tear resistance to remove the inordinate stress and increased tensile strength. The raw untreated crankshafts and the li…

Commissioner of Income Tax-IV vs. Delhi Press Patra Prakashan Ltd

ITA-302/2002HC Delhi31 May 2013
For Appellant: Mr N.P. SahniFor Respondent: Mr O.P. Dua, Sr. Adv. with Ms Babita
Section 143(1)Section 260ASection 80

…ughen them to the requisite standards, so that they could be sold in the market. The activity was held to be manufacturing and entitled to claim deductions. Similarly in the case of CIT v. Tamil Nadu Heat Treatment and Fetting Services (P) Ltd. (No. 1) [1999] 238 ITR 529 (Mad), it was held that the process of heat treatment to crankshaft, etc., were absolutely essential for rendering it marketable. Automobile parts, as crankshafts, need to be subjected to heat treatment to increase the wear and tear resistance to remove the inordinate stress and increased tensile strength. The raw untreated crankshafts and the li…

Commissioner of Income Tax-IV vs. Delhi Press Patra Prakashan Ltd

ITA-151/2002HC Delhi31 May 2013
For Appellant: Mr N.P. SahniFor Respondent: Mr O.P. Dua, Sr. Adv. with Ms Babita
Section 143(1)Section 260ASection 80

…ughen them to the requisite standards, so that they could be sold in the market. The activity was held to be manufacturing and entitled to claim deductions. Similarly in the case of CIT v. Tamil Nadu Heat Treatment and Fetting Services (P) Ltd. (No. 1) [1999] 238 ITR 529 (Mad), it was held that the process of heat treatment to crankshaft, etc., were absolutely essential for rendering it marketable. Automobile parts, as crankshafts, need to be subjected to heat treatment to increase the wear and tear resistance to remove the inordinate stress and increased tensile strength. The raw untreated crankshafts and the li…

Commissioner of Income Tax vs. M/S Delhi Press Patra Prakashan Ltd

ITR-49-50/1996HC Delhi31 May 2013
For Appellant: Mr N.P. SahniFor Respondent: Mr O.P. Dua, Sr. Adv. with Ms Babita
Section 143(1)Section 260ASection 80

…ughen them to the requisite standards, so that they could be sold in the market. The activity was held to be manufacturing and entitled to claim deductions. Similarly in the case of CIT v. Tamil Nadu Heat Treatment and Fetting Services (P) Ltd. (No. 1) [1999] 238 ITR 529 (Mad), it was held that the process of heat treatment to crankshaft, etc., were absolutely essential for rendering it marketable. Automobile parts, as crankshafts, need to be subjected to heat treatment to increase the wear and tear resistance to remove the inordinate stress and increased tensile strength. The raw untreated crankshafts and the li…

The Commissioner of Income Tax vs. Delhi Press Patra Prakashan Lt

ITA - 480 / 2005HC Delhi31 May 2013
For Appellant: Mr N.P. SahniFor Respondent: Mr O.P. Dua, Sr. Adv. with Ms Babita
Section 143(1)Section 260ASection 80

…ughen them to the requisite standards, so that they could be sold in the market. The activity was held to be manufacturing and entitled to claim deductions. Similarly in the case of CIT v. Tamil Nadu Heat Treatment and Fetting Services (P) Ltd. (No. 1) [1999] 238 ITR 529 (Mad), it was held that the process of heat treatment to crankshaft, etc., were absolutely essential for rendering it marketable. Automobile parts, as crankshafts, need to be subjected to heat treatment to increase the wear and tear resistance to remove the inordinate stress and increased tensile strength. The raw untreated crankshafts and the li…

CIT vs. Delhi Press Patra Prakashan Ltd

ITA - 302 / 2002HC Delhi31 May 2013
For Appellant: Mr N.P. SahniFor Respondent: Mr O.P. Dua, Sr. Adv. with Ms Babita
Section 143(1)Section 260ASection 80

…ughen them to the requisite standards, so that they could be sold in the market. The activity was held to be manufacturing and entitled to claim deductions. Similarly in the case of CIT v. Tamil Nadu Heat Treatment and Fetting Services (P) Ltd. (No. 1) [1999] 238 ITR 529 (Mad), it was held that the process of heat treatment to crankshaft, etc., were absolutely essential for rendering it marketable. Automobile parts, as crankshafts, need to be subjected to heat treatment to increase the wear and tear resistance to remove the inordinate stress and increased tensile strength. The raw untreated crankshafts and the li…

Commissioner of Income Tax

ITA/302/2002HC Delhi31 May 2013
For Appellant: Mr N.P. SahniFor Respondent: Mr O.P. Dua, Sr. Adv. with Ms Babita
Section 143(1)Section 260ASection 80

…ughen them to the requisite standards, so that they could be sold in the market. The activity was held to be manufacturing and entitled to claim deductions. Similarly in the case of CIT v. Tamil Nadu Heat Treatment and Fetting Services (P) Ltd. (No. 1) [1999] 238 ITR 529 (Mad), it was held that the process of heat treatment to crankshaft, etc., were absolutely essential for rendering it marketable. Automobile parts, as crankshafts, need to be subjected to heat treatment to increase the wear and tear resistance to remove the inordinate stress and increased tensile strength. The raw untreated crankshafts and the li…

Commissioner of Income Tax

ITA/151/2002HC Delhi31 May 2013
For Appellant: Mr N.P. SahniFor Respondent: Mr O.P. Dua, Sr. Adv. with Ms Babita
Section 143(1)Section 260ASection 80

…ughen them to the requisite standards, so that they could be sold in the market. The activity was held to be manufacturing and entitled to claim deductions. Similarly in the case of CIT v. Tamil Nadu Heat Treatment and Fetting Services (P) Ltd. (No. 1) [1999] 238 ITR 529 (Mad), it was held that the process of heat treatment to crankshaft, etc., were absolutely essential for rendering it marketable. Automobile parts, as crankshafts, need to be subjected to heat treatment to increase the wear and tear resistance to remove the inordinate stress and increased tensile strength. The raw untreated crankshafts and the li…

Commissioner of Income Tax

ITA/480/2005HC Delhi31 May 2013
For Appellant: Mr N.P. SahniFor Respondent: Mr O.P. Dua, Sr. Adv. with Ms Babita
Section 143(1)Section 260ASection 80

…ughen them to the requisite standards, so that they could be sold in the market. The activity was held to be manufacturing and entitled to claim deductions. Similarly in the case of CIT v. Tamil Nadu Heat Treatment and Fetting Services (P) Ltd. (No. 1) [1999] 238 ITR 529 (Mad), it was held that the process of heat treatment to crankshaft, etc., were absolutely essential for rendering it marketable. Automobile parts, as crankshafts, need to be subjected to heat treatment to increase the wear and tear resistance to remove the inordinate stress and increased tensile strength. The raw untreated crankshafts and the li…

CIT vs. Sadhu Forging Ltd

ITA - 351 / 2011HC Delhi03 Jun 2011
Section 37Section 80Section 80I

…t in order to toughen them to the requisite standards, so that they could be sold in the market. The activity was held to be manufacturing and entitled to claim deductions. Similarly in the case of CIT v. Tamil Nadu Heat Treatment & fetting Services (P) Ltd., 238 ITR 529 (Mad), it was held that the process of heat treatment to crankshaft, etc. were absolutely essential for rendering it marketable. Automobile parts, as crankshafts, need to be subjected to heat treatment to increase the wear and tear resistance to remove the inordinate stress and increased tensile strength. The raw untreated crankshafts and the lik…

CIT vs. Sadhu Forging Ltd

ITA - 167 / 2011HC Delhi03 Jun 2011
Section 37Section 80Section 80I

…er to toughen them to the requisite standards, so that they could be sold in the market. The activity was held to be manufacturing and entitled to claim deductions. Similarly in the case of CIT v. Tamil Nadu Heat Treatment & fetting Services (P) Ltd., 238 ITR 529 (Mad), it was held that the process of heat treatment to crankshaft, etc. were absolutely essential for rendering it marketable. Automobile parts, as crankshafts, need to be subjected to heat treatment to increase the wear and tear resistance to remove the inordinate stress and increased tensile strength. The raw untreated crankshafts and…

M/S Titanor Components Ltd vs. CIT & Anr

ITA - 24 / 1999HC Delhi04 Feb 2011
For Appellant: Mr.C.S. Jain and Mr. G. Tushar Rao, AdvocatesFor Respondent: Ms. Prem Lata Bansal, Advocate
Section 260ASection 80Section 80I

…rt of his submissions the learned counsel relied upon the following : CIT vs Oracle Software India ltd. (2010) 2 SCC 677; Vijay Ship Breaking Corpn. & Ors. vs CIT (2008) 14 DTR (SC) 74; CIT vs Tamil Nadu Heat Treatment and Fetting Services (P.) Ltd. (1999) 238 ITR 529; CIT vs Laxmi Art Studio (2001) 249 ITR 710; and CIT vs Emptee Poly-Yarn Private Limited (2010) 2 SCC 720. 9. As against this, Ms Bansal largely relied upon the judgment of the Tribunal and the authorities below. In particular, Ms Bansal stressed upon the fact that what the assessee had undertaken was job work and, in lieu thereof, the c…

CIT v. Tamil Nadu Heat Treatment and Fetting Services (P) Ltd. (No. 1) (238 ITR 529) — Cited in 12 Judgments | BharatTax