Law:

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Section 80-IA of the Income-tax Act, 1961 - Deductions - Profit and gains from infrastructure undertakings - Assessment year 2000-01 - Activity of assessee of manufacturing of voter identity cards amounted to 'manufacture' and consequently, assessee was entitled for benefit under section 80-IA [In favour of assessee] The assessee, engaged in preparing of voter identity card, claimed deduction under section 80-IA. The benefit of deduction under section 80-IA was denied on the plea that voter identity card could not be understood as 'goods'. Held that the assessee for preparation of photo identity cards had to process the data, print the same on the cards, put hologram containing the State emblem, take photograph of the voter, match the photo with the voter's data, affix the same on the cards and laminate the cards and take out the master copy duly laminated, consisting 40 miniatures per page of the above cards for the Election Department. The aforesaid activity involved making of a new final product from the data with which it started and would, thus, amounted to manufacture or production of an article or thing. Once it was held that the assessee was manufacturing or producing an article or thing, necessarily it had to follow that the assessee was an 'industrial undertaking' and covered under the provisions of section 80-IA. CASES REFERRED TO ITO v. Arihant Tiles & Marbles (P.) Ltd. [2010] 320 ITR 79/186 Taxman 439 (SC) (para 10) and CIT v. N.C. Budharaja & Co. [1993] 204 ITR 412/70 Taxman 312 (SC) (para 10). Yogesh Putney for the Appellant. Ms. Radhika Suri for the Respondent. JUDGMENT Ajay Kumar Mittal, J. - This order shall dispose of I. T. A. Nos. 302, 303, 304, 316 and 361 of 2008 as according to learned counsel for the parties, common questions of law and facts are involved therein. For brevity, the facts are being taken from I. T. A. No. 302 of 2008. 2. This appeal has been filed by the Revenue under section 260A of the Income-tax Act, 1961 (in short "the Act"), against the order dated August 10, 2007, passed by the Income-tax Appellate Tribunal, Chandigarh Bench "A", Chandigarh (hereinafter referred to as "the Tribunal"), in I. T. A. No.…

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