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(iii) Even if any simple duplication of some software was carried out by the appellant, it does not qualify as manufacturing for deduction u/s 80IA of the Act."

6. The ld CIT(A) has categorically held in para 7.13 and 7.14 that appellant has not explained even the basic process for development of software, fulfilling the capability of its staff. During the course of hearing on query from the bench about the nature of the software developed and the computer language which was used for development of software and availability sources codes thereof of the ld AR of the appellant could not explain it. Further, it was also submitted that during the course of hearing that the business of the assessee was carried out only for one year. In view of the above startling facts, it is apparent that the assessee has failed miserably to substantiate its claim that it manufacture Indican Software VS ITO ITA NO 248 CHD 2013 A Y 2000-01 software, profit from which is eligible for deduction u/s 80IA of the Act. Therefore we confirm the finding of the ld CIT(A) in confirming the disallowance of deduction of Rs. 14.46 lakhs as well as confirming the rejection of the book results applying the provisions of section 145 rws 144 of the Act and considering only 5% of the income of the Assessee as business income and balance 95% as income from other sources. In the result all the grounds of the appeal of the assessee is dismissed.