LegalAware
LegalAware.ai
EMPOWERING LEGAL AWARENESS

Real judgements, distilled

Legal Case Shots

Court judgements broken down into the case type, how the decision played out, and the lesson worth remembering, with the full judgement available as a PDF.

Frequently asked questions

Is this suitable for use in legal research and court filings?+

Legal Case Shots is built to help you quickly identify and understand relevant precedent. For citation in pleadings or filings, always verify against the full judgment PDF and current citation format (e.g., 2026 INSC ___).

How is a "lesson learnt" different from the judgment's holding?+

The holding is what the court legally decided. The lesson learnt translates that into a practical takeaway: what a lawyer should factor into case strategy or client advice as a result of this precedent.

Is the full judgment available, or just a summary?+

Both. Each case shows a distilled summary (case type, key holding, and lesson learnt) and links to the full judgment as a PDF for when you need the complete text for research or citation.

Can I filter judgments by date or case type?+

Yes. Use Advanced Filters to narrow results by decision date and by practice area, including Constitutional Law, Criminal Law, Service & Administrative Law, Family Law, Civil Property & Inheritance, and Labour & Industrial Law.

Can I search judgments by a specific judge?+

Yes. You can filter judgments by the judge or bench that decided the case, which is useful for tracking how a particular judge has reasoned on similar issues across multiple rulings.

What is Legal Case Shots?+

Legal Case Shots is a searchable database of Supreme Court of India judgments, each broken down into the case type, the court's key holding, and a practical lesson learnt, with the full judgment available as a PDF for citation or deeper reading.

Tax & Customs LawSupreme Court of India

M/s Polyflex (India) Pvt. Ltd. vs. The Commissioner of Income Tax & Another

Civil Appeal · 2022 INSC 1211Decided 17 Nov 2022
Civil Appeal No. 8260 of 2022
M.R. Shah · M.M. Sundresh

Background

Polyflex (India) Pvt. Ltd. manufactured polyurethane foam (from the chemicals Polyol and Isocyanate) at its Pune unit, which was ultimately used by others as automobile seats. The company claimed a tax deduction under Section 80-IB of the Income Tax Act for the assessment year 2003-04, but the Assessing Officer disallowed it, holding that polyurethane foam fell under Entry 25 of the Eleventh Schedule to the Act: goods excluded from Section 80-IB benefits. The Commissioner of Income Tax (Appeals) upheld this, but the Income Tax Appellate Tribunal (ITAT) reversed it, holding the assessee's real end-product was the automobile seat, not polyurethane foam. The Karnataka High Court then set aside the ITAT's order and restored the disallowance, prompting the assessee's appeal to the Supreme Court.

Decision Breakdown

The Supreme Court held that what the assessee actually manufactured and sold was polyurethane foam in various sizes and designs. It did not itself carry out any further manufacturing process (such as moulding) to produce a finished automobile seat; that conversion was done later by other "assembly operators" who purchased the foam as a raw ingredient. Since no further process was undertaken by the assessee itself, the finished product it sold remained polyurethane foam, squarely falling within Entry 25 of the Eleventh Schedule. The Court distinguished the case law relied on by the assessee as inapplicable on facts, agreed with the High Court and the tax authorities, and held the deduction under Section 80-IB was rightly denied.

Lesson Learnt

For tax deduction purposes tied to what an assessee itself "manufactures," courts look at the actual state of the product as sold by that assessee, not the eventual end-use by a downstream buyer: merely supplying a raw or intermediate material that someone else later processes into a different, distinct commercial product does not make the original seller the manufacturer of that end product.

Official source (sci.gov.in)View Judgment (PDF)
M/s Polyflex (India) Pvt. Ltd. vs. The Commissioner of Income Tax & Another – Legal Case Shots | LegalAware