Commr.Of Income Tax-V,New Delhi vs M/S Oracle Software India Ltd

The Supreme Court addressed whether the process of transforming a blank Compact Disc (CD) into a software-loaded disc constitutes 'manufacture or processing of goods' under Section 80IA(1) and Section 80IA(12)(b) of the Income Tax Act, 1961. The Court held that the mere act of copying software from Master Media to blank CDs does not amount to manufacture or processing, as there is no change in the character or identity of the software. Consequently, the assessee was denied the deduction under Section 80IA, affirming the Department's stance that duplication does not qualify as manufacturing.