COMMISSIONER OF INCOME-TAX Vs. SRIYANSH KNITTERS

JUDGEMENT

(1.) THE matter here pertains to development rebate, the controversy being whether the entitlement of the assessee was to 15% or 25% of such rebate.

(2.) THE assessee had installed new machinery worth Rs. 7,80,645 during the assessment year 1974-75 and thereafter claimed development rebate in respect of it. The Tribunal allowed 25% development rebate and this is what led the following question to be referred to this court for its opinion :

(3.) ADMITTEDLY, the machinery in question has been used by the assessee for manufacture of woollen hosiery for export. The question that arises is whether item 32 of the Fifth Schedule covers the manufacture of woollen hosiery too. This entry reads as under :