VidhiSangh

Supreme Court of India · 03/08/2017

COMMISSIONER OF INCOME TAX- 1, MUMBAI versus M/S. HINDUSTAN PETROLEUM CORPORATION LTD.

[2017] 7 S.C.R. 631 · 2017 INSC 706

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Summary

The complex technical activity of bottling LPG for domestic use constitutes production for deductions under Sections 80HH, 80-I and 80-IA. Those provisions cover production as well as manufacture, and the assessing authority erred by applying only a narrower manufacture test. The Revenue’s appeals against allowance of the deductions were dismissed.

Issues

  1. Whether domestic LPG bottling constitutes production or manufacture for the relevant income-tax deductions.

Held

Result

Revenue’s appeals dismissed; Tribunal’s allowance of deductions, as affirmed by the High Court, upheld.

Judgment PDF: Supreme Court of India, [2017] 7 S.C.R. 631.