Tribunal held that extraction and processing of iron ore amounted to production. Electric energy would be covered under the definition of “goods” and generation of power would amount to manufacture or production of goods. Therefore, the assessee was eligible for allowance under section 32AC of the Act. Followed, CST v. Madhya Pradesh Electricity Board (1970) 25 STC 188 (SC) and PCIT v. NTPC Sail Power Co. P Ltd (2020)428 ITR 535 (Delhi)(HC) (AY. 2014-15)
Vedanta Ltd. v. ACIT (2020) 84 ITR 84 (Delhi)(Trib.)
S. 32AC : Investment in new pant or machinery-Generation of power amounts to manufacture or production of goods-Eligible for allowance.