Manufacture – Section 2(69) | Income-tax Act, 2025 vs 1961
Manufacture
Means, with its grammatical variations and cognate expressions, a change in a non-living physical object or article or thing — (a) resulting in transformation of the object or article or thing into a new and distinct object or article or thing having a different name, character and use; or (b) bringing into existence of a new and distinct object or article or thing with a different chemical composition or integral structure.
- Maps to Section 2(29BA) of the 1961 Act — identical definition in both Acts covering two distinct limbs of manufacture
- Relevant for investment allowance and area-based deductions under the 2025 Act where manufacturing activity is a qualifying condition
- Assembling, packing, or labelling alone does not qualify as manufacture — there must be transformation or creation of a new and distinct product
Courts have held that mere repacking or labelling is NOT manufacture — there must be a transformation creating a new and distinct product.
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