| Case ID |
1580b398-e756-4c1c-8bbe-027c40d6599d |
| Body |
View case body. Login to View |
| Case Number |
Civil Appeals Nos. 144 to 146 of 1994 |
| Decision Date |
Mar 18, 1999 |
| Hearing Date |
|
| Decision |
The Supreme Court dismissed the appeals of Stone Craft Enterprises, affirming the Karnataka High Court's decision that granite is considered a 'mineral' under Section 80HHC of the Indian Income Tax Act, 1961. The court ruled that the special deduction provided under this section does not apply to profits derived from the export of granite, as it is categorized along with minerals and ores, which are explicitly excluded from the benefits of this section. The court emphasized the importance of interpreting the term 'minerals' in a manner consistent with the doctrine of noscitur a sociis, thereby confirming the view that all minerals extracted from the earth, including granite, fall under the provisions that restrict deductions for exports. Consequently, the court held that the profits from the export of granite dimensional blocks do not qualify for the special deduction under Section 80HHC for the assessment years 1985-86, 1987-88, and 1988-89. |
| Summary |
In the case of Stone Craft Enterprises vs. Commissioner of Income Tax, the Supreme Court of India addressed the interpretation of Section 80HHC of the Indian Income Tax Act, 1961, concerning the classification of granite as a mineral. The court ultimately ruled that granite is indeed a mineral and, as such, profits from its export do not qualify for the special deductions available under the Act. This ruling is significant as it clarifies the tax implications for businesses involved in exporting granite and highlights the court's reliance on established doctrines for statutory interpretation. The case reaffirms the context-dependent nature of legal definitions and the importance of adhering to legislative exclusions. Notably, the court referenced previous judgments and circulars issued by the Central Board of Direct Taxes to substantiate its decision, emphasizing the need for clarity in tax law as it pertains to natural resources and their classifications. This decision is pivotal for businesses in the mining and export sectors, particularly those dealing with granite, as it sets a precedent regarding the tax treatment of such exports. Keywords: granite export, mineral classification, tax deduction, Indian Income Tax Act, legal interpretation. |
| Court |
Supreme Court of India
|
| Entities Involved |
Not available
|
| Judges |
S. P. Bharucha,
R. C. Lahoti
|
| Lawyers |
A.K. Ganguli, Senior Advocate,
M.T. George, Advocate,
V. Gaurishanker, Senior Advocate,
S. Rajappa, Advocate
|
| Petitioners |
Stone Craft Enterprises
|
| Respondents |
Commissioner of Income Tax
|
| Citations |
2001 SLD 233,
2001 PTD 1755,
(1999) 237 ITR 131,
(2000) 81 TAX 176
|
| Other Citations |
Stonecraft Enterprises v. CIT (1993) 204 ITR 550,
Banarsi Dass Chadha & Bros. v. Lt.-Governor, Delhi Administration AIR 1978 SC 1587,
Pardeep Agarbatti v. State of Punjab (1997) 107 STC 561,
State of Mysore v. Swamy Satyanand Sarswati AIR 1971 SC 1569
|
| Laws Involved |
Indian Income Tax Act, 1961
|
| Sections |
80HHC
|