Court : Income Tax Appellate Tribunal ITAT Delhi
Reported in : (1983)6ITD575(Delhi)
..... power houses, tunnels, culverts, drains, channels, sewages, gardens and pleasure gardens and all sorts of contracts for procurement and supply for local, municipal, state, central authorities, government departments, railways, universities or for any other person, firms or companies. 2. to undertake the construction of every description and to erect, rebuild, enlarge, alter, pull down ..... so what is that article or articles. we are inclined to follow the decision of the gujarat high court in the case of cellulose products of india ltd. (supra) and hold that the 'articles' should only mean the end-product and not the intermediate product. their lordships of the gujarat high ..... section 80hh. there also, the assessee-firm was undertaking the construction of an irrigation project. the commissioner in a proceeding under section 263 of the act had held that the assessee was not manufacturing or producing articles and, therefore, it was not eligible for deduction under section 80hh. the tribunal had .....
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