Assessee is engaged in business of manufacture and production lube oil.. During relevant assessment year it commissioned lubricants blending plant and claimed investment allowance under section 32AC of the Act. Assessing Officer disallowed claim holding that blending process undertaken by assessee-company did not amount to manufacture or production of an article or thing and that threshold limit of investment of INR 100 crores as prescribed under section 32AC was not met.CIT(A) allowed the claim. On appeal the Tribunal held that blending of lube oil tantamounts to manufacture or production as contemplated under section 32AC. Since revenue could not controvert claim of assessee that it had made investment exceeding threshold limit and fact that installation of plant & machinery had been completed during year under consideration was not in dispute at all, assessee was entitled to investment allowance as claimed. (AY.2014-15)
ACIT v. Idemitsu Lube (P.) Ltd. (2024) 207 ITD 173 /111 ITR 59 (SN) (Delhi) (Trib.)
S. 32AC: Investment in new pant or machinery-Installation of machinery-Blending of lube oil tantamounts to manufacture or production-Entitle to deduction.
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