{"id":125959,"date":"1992-02-12T00:00:00","date_gmt":"1992-02-11T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/assistant-commissioner-of-vs-om-prakash-agrawal-on-12-february-1992"},"modified":"2016-06-04T18:45:20","modified_gmt":"2016-06-04T13:15:20","slug":"assistant-commissioner-of-vs-om-prakash-agrawal-on-12-february-1992","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/assistant-commissioner-of-vs-om-prakash-agrawal-on-12-february-1992","title":{"rendered":"Assistant Commissioner Of … vs Om Prakash Agrawal on 12 February, 1992"},"content":{"rendered":"
Income Tax Appellate Tribunal – Jaipur<\/div>\n
Assistant Commissioner Of … vs Om Prakash Agrawal on 12 February, 1992<\/div>\n
Equivalent citations: 1992 43 ITD 359 JP<\/div>\n
Bench: V Elhence, J Verma<\/div>\n<\/p>\n
<\/pre>\n
ORDER<\/p>\n
J.K. Verma, Accountant Member<\/p>\n
1. The assessee-flrm carried on the business of execution of contract work for Food Corporation of India at various places. Although it has not come out specifically from the orders of authorities below, it was submitted before us that the work consisted of construction of godowns (or the Food Corporation of India. The only question involved in this appeal filed by the Revenue is whether on the facts and in the circumstances of the case the learned CIT(A) erred in holding that construction work is also an activity of production and, therefore, it is an Industrial Undertaking within the meaning of Section 32A of the IT Act and, therefore, entitled to investment allowance. The learned Sr. Departmental Representative referred to the decision of the Hon’ble Bombay High Court in the case of Shah Construction Co. Ltd. v. CIT [1991] 188 ITR 537 (Bom.) where it has been held that construction of wells, roads, dams, canals etc. did not amount to production or manufacturing of articles or things and hence that assessee was not entitled to benefit of investment allowance. He submitted that similar views were expressed by their Lordships in the case of CIT v. Shah Construction Co. Ltd. [1983] 142 ITR 696 (Bom.). The Id. Departmental Representative submitted that the provisions of Section 32A(2)(b)(iii) showed that it was only under that Sub-clause that the word “construction” was included whereas it was not included under Sub-clause (ii) of Section 32(2)(b). He further argued that in any case construction of godowns could not be said to be manufacture or production of any article or thing.\n<\/p>\n
2. The learned counsel for the assessee argued that as held by the Hon’ble Karnataka High Court in the case of Shankar Construction Co. v. CIT[1991] 189 ITR 463, building was included in the category of “thing”. The learned counsel further referred to the decision in Shantlal Ishverbhai Patel v. JTO [1990] 38 TTJ (Ahd.) 290 so also the decisions in the cases of Walaiti Ram Gupta & Co. v. no [1990] 33 ITD 544 (Delhi) and Modern Syntex (India) Ltd. v. JTO [1987] Tax World 131 (Jp.) to argue that in those cases also the benefit of investment allowance had been granted although those assessees were engaged in construction activities. He further submitted that in the cases of CIT v. Oricon (P.) Ltd. [1985] 151 ITR 296 (Bom.), ITO v. R. Sivaraman [1989] 31 ITD 338 (Mad.) and Popular Automobiles v. IAC [1991] 41 TTJ (Coch.) 322, the benefit of investment allowance was given where the assessees were engaged in construction works.\n<\/p>\n
3. We have carefully considered the arguments from both the sides and have perused the material on record so also the provisions of Section 32A. We find that Section 32A(2)(b), which prescribes the categories of assessees who would be entitled to investment allowance, contains three Sub-clauses. Sub-clause (i) mentions those assessees who are engaged in the business of generation or distribution of electricity or any other form of power and in all those cases the benefit of investment allowance is available. That matter is not in dispute before us. However, Sub-clauses (ii) and  (iii) of Section 32A(2)(b) prescribe those other categories of assessees who instal plant and machinery and would be entitled to this benefit. They are relevant for our purpose and they read as under :\n<\/p>\n
(ii) in a small-scale industrial undertaking for the purposes of business of manufacture or production of any article or thing; or<\/p>\n
(iii) in any other industrial undertaking for the purpose of business of construction, manufacture or production of any article or thing, not being an article or thing specified in the list in the Eleventh Schedule.\n<\/p>\n
It can be easily noticed that while both the Sub-clauses provide for allowing investment allowance to industrial undertakings who use the plant and machinery for the purposes of business of manufacture or production of any article or thing, Sub-clause (ii) provides the benefit to small-scale industrial undertakings whereas Sub-clause (iii) provides the benefit to any other industrial undertaking. However, while on the one hand Sub-clause (iii) enlarges the scope for giving the benefit of investment allowance to any other indiastrial undertaking in contradistinction to the small-scale industrial undertaking which is covered in Sub-clause (ii), it also enlarges the scope by including the business of construction in addition to the business of manufacture or production of any article or thing. It may further be noticed that whereas Sub-clause (ii) provides this benefit to small-scale industrial undertakings carrying on business of manufacture or production of any article or thing, Sub-clause (iii) while enlarges the scope to include the business of construction also, restricts the scope to the construction, manufacture or production of any article or thing, not being an article or thing specified in the list in the Eleventh Schedule. The inferences which emerge and which are relevant for us are that whereas a small-scale industrial undertaking is entitled to benefit of investment allowance only if it carries on the business of manufacture or production of any article or thing, any other industrial undertaking is entitled to this benefit even if it carries on the business of construction. Even if we accept the arguments of the learned counsel for the assessee that the article or thing includes a building also, it would mean that an assessee who is engaged in the business of construction of a building or a godown would be entitled to the benefit of investment allowance only if it is “any other” industrial undertaking and not a small-scale industrial undertaking. As per clause (2) of Explanation to Section 32A(2), an industrial undertaking shall be deemed to be a small-scale industrial undertaking, if the aggregate value of the machinery and plant (other than tools, jigs, dyes and moulds) installed, as on the last day of the previous year for the purposes of the business of the undertaking does not exceed (for the purposes of our relevant assessment year 1986-87) Rs. 35 lacs. It was admitted by the Id. counsel for the assessee that as per the Balance Sheet of the assessee the total working capital of the assessee, including the capital of the partners and the loans, was about Rs. 23 lacs. This would mean that in the instant case the aggregate of the machinery and plant of the assessee installed for the purposes of business of the undertaking would not exceed Rs. 35 lacs and hence the assessee would be deemed to be a small-scale industrial undertaking. The consequence is obvious viz. that it shall be covered by the provisions of Sub-clause (ii) of Section 32A(2)(b) of the Act which does not cover the business of construction. Hence as discussed by us in the preceding part of this paragraph, the assessee being a small-scale industrial undertaking would not be entitled to the benefit of investment allowance because even if we accept the arguments of the learned counsel for assessee that the building or the godown may be an article or a thing, it can certainly NOT be said that buildings or godowns are manufactured or produced. We agree with the submissions of the learned Departmental Representative that since the words ‘manufacture’, ‘production’ and ‘construction’ have not been defined in the Income-tax Act, they have to be understood in their ordinary sense and hence it can only be said that the building or a godown is constructed and not manufactured or produced. Of course, if the assessee had been an industrial undertaking other than a small-scale industrial undertaking, it could have been entitled to the benefit of the investment allowance in respect of machinery or plant installed for the purposes of business of construction of godowns or the buildings, because then it should have been covered by the provisions of Sub-clause (iii) of Section 32A(2)(b) of the Act.\n<\/p>\n
4.  Examined in this back-ground it is obvious that the case law cited by the Id. counsel for the assessee does not help him because almost all those cases dealt with the question as to whether the assessee concerned could be said to be an industrial undertaking or whether an assessee engaged in construction work could be said to be an industrial undertaking. Only in the case of Shantilal Ishverbhai Patel (supra) the question of “construction” was considered and it was held that where an assessee was engaged in construction business, the business of manufacture or production also, in addition to construction business, was not required. In none of those cases it is discussed or specified as to whether they were small-scale industrial undertakings or any other industrial undertakings. But the very fact that in those cases the benefit of investment allowance had been given while they were carrying on the business of construction, makes it obvious that they must have been industrial undertakings other than small-scale industrial undertakings and were covered by the provisions of clause (iii) of Section 32A(2)(b). No case has been brought to our notice to show that in spite of the fact that an assessee was a small-scale industrial undertaking and had used the plant and machinery for the purposes of business of construction, it was allowed the benefit of investment allowance.\n<\/p>\n
5. Even if we accept all the arguments of the Id. counsel for the assessee based on the case law mentioned above, the situation which may emerge is that the assessee before us which is engaged in construction activity, may be treated as an industrial undertaking, and in order to get the benefit of investment allowance may not be required to carry on manufacturing or production work – as held in the case of Shantilal Ishverbhai Patel (supra). Nevertheless, one important requirement would be missing and that is, being a small-scale industrial undertaking, it would not be falling under the provisions of Section 32A(2)(b)(iii), but would be falling under provisions of Section 32A(2)(b)(ii). As such, the construction business only, carried on by it, will not entitle it to the benefit of investment allowance, because under Section 32A(2)(b)(ii) this benefit is not given to assessees carrying on the business of construction. We find a lot of weight in the submissions of the learned Departmental Representative that the Legislature has not used the word “construction” in Sub-clause (ii) while in the immediately following Sub-clause  (iii)  it has included  the word “construction” and we cannot   read the word “construction” in Sub-clause (it) of Section 32A(2)(b) by implication.\n<\/p>\n
6. We, therefore, hold that since the assessee is a small-scale industrial undertaking and was claimed to be engaged in the business of construction of godowns and buildings, it is not covered either by the provisions of Sub-clause (ii) or Sub-clause (iii) of Section 32A(b) of the IT Act and is, therefore, not entitled to investment allowance in respect of plant and machinery claimed to have been used for the purposes of business of construction of godowns and buildings.\n<\/p>\n
7. Accordingly, the order of the Id. CIT(A) on this point is reversed and the appeal filed by the Revenue is allowed.<\/p>\n","protected":false},"excerpt":{"rendered":"
Income Tax Appellate Tribunal – Jaipur Assistant Commissioner Of … vs Om Prakash Agrawal on 12 February, 1992 Equivalent citations: 1992 43 ITD 359 JP Bench: V Elhence, J Verma ORDER J.K. Verma, Accountant Member 1. The assessee-flrm carried on the business of execution of contract work for Food Corporation of India at various places. […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_lmt_disableupdate":"","_lmt_disable":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[1],"tags":[],"class_list":["post-125959","post","type-post","status-publish","format-standard","hentry","category-judgements"],"yoast_head":"\nAssistant Commissioner Of ... vs Om Prakash Agrawal on 12 February, 1992 - Free Judgements of Supreme Court & High Court | Legal India<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.legalindia.com\/judgments\/assistant-commissioner-of-vs-om-prakash-agrawal-on-12-february-1992\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Assistant Commissioner Of ... vs Om Prakash Agrawal on 12 February, 1992 - 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