Attributable to Income Tax Act, 1961, Ss. 80-E & 80-I The industry being carried on by the assessee is admittedly a priority industry as defined in S. 80-B(7). The only question is whether the profits and gains arising from import and sale of spare parts can be said to be “attributable to … priority industry” being carried on by the assessee. The Tribunal has found that the assessee commenced manufacturing Ashok Leyland trucks in collaboration with a foreign company Leylond from about 1966 onwards. There was a phased programme for the manufacture of necessary spare parts. It was found that some of the purchasers of the trucks from the assessee found it difficujlt during some years to get the requisite spare parts either because the spare parts manufactured by the assessee were not sufficient to meet the demand or because the assessee did not manufacture those particular pare parts. In the said circumstances and as a matter of commercial expediency, the assessee imported such spare parts and sold them during the accounting years relevant to the assessment years concerned herein. It is on these facts that the question referred has to be answered. We are of the opinion that reading the relevant portion of sub-section(1) of S. 80-I along with the definition of “priority industry” in S. 80-B(7), it must be held that the profits and gains arising from import and sale of spare parts was attributable to the industry (priority industry) carried on by the assessee. (Ashok Leyland Ltd v. C.I.T. (1997) 1 SCC 729 (731)