Section 80-IC of the Income Tax Act

A new industrial undertaking is not considered a reconstruction of an existing business for tax deduction purposes if it is a separate, independent production unit manufacturing commercially tangible products that can operate without losing its identity in the old business. The transfer and substantial use of assets and manpower from an old business to a new one may indicate reconstruction.

Interest earned from the temporary parking of borrowed funds specifically intended for project development, prior to the commencement of business, constitutes a capital receipt inextricably linked to the project and is not taxable as 'income from other sources'.

For the purpose of claiming deductions under sections like 10B, 80IC, 80HHC, 80J, and 80I, a process must amount to 'manufacture' as defined under Section 2(29BA), involving genuine value addition or chemical transformation.

The activity of converting jumbo rolls of photographic films into smaller flats and rolls of desired sizes constitutes 'manufacture'. This principle clarifies that 'manufacture' includes processes that transform raw or prepared materials into articles for use by changing their form or utility.

The transformation of bulk powder into regulated, consumable capsules constitutes manufacturing under the definition provided in various statutes, qualifying for associated tax benefits and deductions.

The definition of 'production' includes mining activities aimed at producing mineral ores, as ore is a result of human effort or process. This interpretation, originating from the Oxford English Dictionary, establishes that mining falls within the ambit of production.

When an existing unit undertakes substantial expansion under Section 80-IC, the previous year in which the expansion occurs becomes the initial assessment year, entitling the unit to 100% deduction for 10 years from that year.

Whether a commercial commodity has been transformed into a different commercial commodity with a distinct character, use, and name is a factual determination that depends on the specific circumstances of the case.

Salary paid to a partner is merely a mode of sharing profits and retains the character of the firm's income. The payment is an adjustment of the amount the partner is entitled to receive based on their contribution of human capital, skill, and toil.

Goodwill and commercial rights acquired before April 1, 2012, are not eligible for depreciation under Section 32(1)(ii) if they are not block assets. The depreciable nature of an asset depends on its inclusion in the block of assets.