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Commissioner Of Income Tax 1 vs M/S. Hindustan Petroleum Corporation ... on 3 August, 2017

13. From perusal of the above finding of ld. CIT(A) given in the order u/s 250 of the Act as well as u/s 154 of the Act allowing the assessee's claim for deduction u/s 80IC/80IE of the Act for the units located at Sivasagar, North Lakhimpur and Duliajan, we note that ld. CIT(A) has followed the ratio laid down by the Hon'ble Apex Court in the case of Hindustan Petroleum Corpn. Ltd. (supra) and has analysed the details and the process carried out by the assessee of converting the liquid oxygen into oxygen in gaseous form and also observing that bulk LPGs is received in the bottling plants located at respective units and then unloading in the spheres/bullets through LPG compressors having variable levels of pressure for suction, unloading and vapour recovery and thereafter refilling/bottling of the LPG in cylinders and then conversion of the same in gaseous form for the industrial and medical consumers and after analysing this process ld. CIT(A) has rightly arrived to the conclusion that the assessee is engaged in the production activity and thus, eligible for deduction u/s 80IC/80IE of the Act.
Supreme Court of India Cites 19 - Cited by 49 - A K Sikri - Full Document
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