The assessee claimed the allowance under Section 80HH of the Income Tax Act, 1961, on the ground that it was an industrial undertaking that manufactured produced articles.
The Income Tax Officer negatived the claim.
It would appear from the judgment of the Tribunal that the assessee bought shrimps, peeled them and froze them.
The Commissioner of Income Tax Appeals and the Tribunal upheld the claim.
From the order of the Tribunal the question aforementioned was referred to the High Court for its opinion.
There is numberother material on the record which indicates what was done by the assessee and how it was done.
P. Bharucha, J. The only question with which we are companycerned in this appeal by the Revenue, relating to the Assessment Year 1977 78, reads thus Whether, on the facts and in the circumstances of the case i the assessees business involves production ?
ii the assessee is entitled to exemption under Section 80HH of the 1.T. Act, 1961?
