PCIT v. Sona Vets Pvt. Ltd. (2020) 424 ITR 387/ 193 DTR 294/ 316 CTR 569/ 275 Taxman 578 (Cal)(HC)

S. 80IB: Industrial undertakings -Manufacture- Making of poultry feed amounts to manufacture — Commercially different and distinct as a commodity – Entitle to deduction [ S .2(29BA ]

Dismissing the appeal of the revenue the Court held that the  poultry feed was not merely rice bran or maize or vitamins or minerals but a mixture of all in calculated proportions through a process involving mills and manufacturing by the use of machinery which ran on electricity and where the end product being the pellet was wholly different from each of the ingredients and resulted in a product which was commercially different and distinct as a commodity so that it could not be considered as any of the original commodities which were used as ingredients. The assessee which was producing poultry feed was entitled to the special deduction.  ( AY.2009-10, 2010-11, 2012-13, 2013-14)

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