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26. In respect of above claim, the assessee has given written submissions which have been stated by ld CIT(A) in para 4.1 which reads as under:

"EPL (Essel Propack Limtied) is in the business of manufacturing Lamitubes, it provides packaging solutions in dentifrice, cosmetics and pharmaceutical sectors to global major in these businesses. Lamitubes are required to be printed as per each customer unique designs, drawing shade and other artwork given by each customer. The process of printing is carried by rotary letter printing press printing method which involves a central impression drum involving 6 stations of which the last station is varnishing station. The drying mechanism is with the help of UV radiation and graphic is the back bone of printing process before printing it is necessary to develop the basic design, negatives, positives, step and repeat and nyloplates for printing department.