On appeal the High Court held, following the principle laid down in CIT v Oracle Software India Ltd (2010)320 ITR 546 ( SC) and considering the facts that (i) the activity of video software generation has been recognized as small scale industries by Government of India and (ii) providing the audio software to the video already shot makes an article fit for use, it tantamount to manufacture within the meaning of provisions of S. 80IB of the Act. (ITA No. 108 of 2012, dt. 08/08/2017) ( AY.2001-02)
Vijay Kumar v CIT (2018) 161 DTR 278 /300 CTR 254 (J&K)(HC)
S. 80IB : Industrial undertakings – Activity of supplying the audio of the background sound to the film already shot by customers is manufacture and entitle to deduction.