“Section 80(8)(2)(a)”
The decision most relied on for Section 80(8)(2)(a) is Indian Cine Agencies v. CIT (308 ITR 98), cited in 59 judgments on BharatTax.
Leading authorities on Section 80(8)(2)(a)
The activity of cutting jumbo roll films into flat and small rolls in desired sizes is considered manufacture or production for the purposes of the Income-tax Act.
For an activity to be considered 'manufacture', it must result in a transformation where a new and different article emerges with a distinctive name, character, or use.
The transfer of assets from an existing unit to a new unit does not automatically attract Section 15C(2)(ii) if the value of the transferred assets is less than twenty percent of the total value of assets of the new unit. This decision clarifies when a new unit's operations are considered distinct from an old unit's operations.
Coal mines are considered plant and machinery and are therefore eligible for investment allowance under Section 32A.
The value of steam used for captive consumption by an assessee is eligible for deduction under section 80-IA of the Income-tax Act, as steam is considered a source of power with a determinable cost of production.
Assembling air purifiers using simple tools and testing equipment constitutes 'manufacture' for the purpose of claiming deductions under Section 80IC of the Income-tax Act, 1961, as the final product is entirely different from its constituent parts.
Education cess is not an allowable deduction under section 37(1) read with section 40(a)(ii) of the Income Tax Act, 1961. This is because it is in the nature of a tax, not an expenditure incurred for the purpose of business.