COMMISSIONER OF INCOME TAX 1 vs M/S. HINDUSTAN PETROLEUM CORPORATION LTD.

The Supreme Court addressed the interpretation of 'manufacturing' under Sections 80HH, 80-I, and 80-IA of the Income Tax Act, 1961, in the context of bottling Liquefied Petroleum Gas (LPG) cylinders. The Court upheld the ITAT's finding that the bottling process constitutes manufacturing, as it involves significant technical operations and quality control, thus qualifying the assessees for tax deductions. The Court affirmed the High Court's decision, rejecting the Revenue's claim that bottling does not amount to manufacturing.