Meaning of “Installed for the purpose of industrial undertaking”

Case Name : Dy. CIT Vs. Samir Diamond Mfg. (P.) Ltd.

Citation :[1998] 67 ITD 25 (AHD. – TRIB.)

Court : ITAT-Ahmedabad

Section : 80HHA

Meaning : The words ‘installed for the purpose of the industrial undertaking’ used in explanation (b) to section 80hha are not superfluous or unnecessary but of vital importance. In case the value of the vehicles, computer system and other items which are not connected with the production of industrial undertaking were to be included in the value of plant and machinery under explanation (b) to section 80hha, the legislature in its wisdom would not have used the words ‘installed for the purpose of the business of the undertaking’ in explanation (b) to section 80hha.

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