COMMR. OF INCOME TAX, BANGALORE vs VENKATESHWARA HATCHERIES — C.A. No. 5066/1996

Summary The Supreme Court held that hatchery businesses do not constitute "industrial undertakings" engaged in "manufacture or production of articles or things" under Sections 32A and 80J of the Income Tax Act. The court reasoned that chick formation is a natural biological process beyond the assessee's control; the hatchery merely preserves eggs at specific temperatures, making hatching an "event of nature" rather than production. Consequently, hatcheries are ineligible for development allowance and industrial deductions claimed by the assessee. This case analysis is maintained by casestatus.in based on publicly available court records.