Tribunal was right in denying
deduction to the assessee under Section 80IC of
the Income Tax Act, 1961, especially when the
Tribunal has itself given ... manufacturing activity,
which is sine quo non for claiming exemption
under Section 80IC of the Income Tax Act, 1961?
b) Whether, in facts and circumstances
Tribunal was right in denying
deduction to the assessee under Section 80IC of
the Income Tax Act, 1961, especially when the
Tribunal has itself given ... manufacturing activity,
which is sine quo non for claiming exemption
under Section 80IC of the Income Tax Act, 1961?
b) Whether, in facts and circumstances
Learned Tribunal erred in law in allowing the benefit under
section 80IC of the Income Tax Act to the tune ... undertaken substantial
expansion of business as is required under section 80IC (2)(b)(iii)
2
of the Act for claiming the benefit of exemption under
claimed
by the petitioner-assessee under Section 80IC of Income Tax Act, 1961 (in
short „the Act‟).
2.3. Aggrieved, by the decision rendered ... held that
deduction u/s 80IC is allowable to the assessee of
Rs.1,88,63,283/- on the net profit arising
right in law in holding that benefit of deduction under
Section 80IC are allowable to only those units which
were existing prior to the year ... facts in holding that undertaking which
has been claimed deduction under Section 80IC is
debarred from claiming further deduction though the
factum of substantial expansion
Fasteners case was no different except that the
provision involved was Section 80IC of the Act. This provision also contained
the expression "derived from ... subsistence of the expression "derived from" in
Sections 80HHC and 80IC of the Act, and second, there was no finding of fact
Signature
assessee.
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15. Issue of allocation of corporate overhead to section
80IC unit beyond what was already allocated by the
assessee was held in favour ... assessee.
16. Issue of eligibility of other income for deduction
u/s. 80IC was held against the assessee.
17. Issue of allocation of corporate overhead
before the 1st day of April, 2009.]”
7.3.According to Sec.80IC(11A) once an assessee in
involved in the processing preservation and packaging
income, after
claiming deduction of Rs. 1,16,47,756/- under Section 80IC of the
Income Tax Act, 1961 (for short ... account
of disallowance of deduction under Section 80IC on income on
account of discount received and addition of Rs.7,13,435/- on
account
after claiming deduction of
Rs.1,22,83,721/- under Section 80IC of the Income Tax Act,
1961 (for short ... assessed at Rs.13,81,278/- by disallowing deduction under
Section 80IC to the extent of income of Rs. 6,44,538/-.
3. The assessee
