Section 32A of the Income Tax Act
The decision most relied on for Section 32A is CIT v. Sesa Goa Ltd. (271 ITR 331), cited in 92 of the 84 judgments on BharatTax that turn on this section.
Leading authorities on Section 32A
Extraction and processing of iron ore constitutes "production" for the purpose of claiming tax benefits like investment allowance under Section 32A and additional depreciation under Section 32(1)(iia), even if it does not amount to "manufacture".
The case clarified that activities like cutting marble blocks into slabs can constitute 'manufacture' for excise purposes, a principle relevant to understanding 'production' under Section 80-IA of the Income Tax Act, even if the earlier judgment did not explicitly interpret 'production'.
The extraction and processing of iron ore, even if not amounting to the manufacture or production of an article or thing, can constitute 'production' for the purposes of claiming deductions under Section 80-IA and depreciation under Section 32-A of the Income Tax Act, 1961.
