TEXTILE MACHINERY CORPORATION LIMITED, CALCUTTA vs THE COMMISSIONER OF INCOME-TAX, WEST BENGAL,CALCUTTA

The Supreme Court interpreted Section 15C of the Indian Income-tax Act, 1922, which provides tax exemptions for newly established industrial undertakings. The Court held that for an undertaking to be considered new and not a reconstruction of an existing business, it must demonstrate substantial fresh capital investment, distinct identity, and independent operation. The Court overturned the High Court's ruling, affirming the Appellate Tribunal's decision that the Steel Foundry and Jute Mill Divisions were indeed new undertakings eligible for tax exemption under Section 15C.