COMMISSIONER OF INCOME TAX, GUJARAT vs CELLULOSE PRODUCTS OF INDIA LTD.

The Supreme Court held that the respondent, a Public Limited Company, was not entitled to relief under Section 84 of the Income Tax Act for the assessment year 1966-67, as it had commenced production of cellulose pulp, an intermediate product, in March 1961, which did not qualify as the manufacture of 'articles' under the Act. The Court affirmed the Tribunal's finding that the last year for which relief was available was the assessment year 1965-66. The High Court's interference was deemed erroneous as it lacked appellate jurisdiction over the Tribunal's decision, which was supported by evidence and not perverse.