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2023 (1) TMI 756 - ITAT MUMBAIDeduction u/s 80IB - part of the manufacturing activity being done from outside unit - HELD THAT:- CIT(A) has passed valid order by taking the view that even if the part of manufacturing activities are being done from outside the unit, the deduction under section 80IB could not be disallowed. This view has also been affirmed by case of Penwalt India Ltd. [1991 (4) TMI 33 - BOMBAY HIGH COURT] and CIT vs. Oricon P. Ltd. [1983 (10) TMI 15 - BOMBAY HIGH COURT] So merely because of the fact that part of the manufacturing process resulting in N products was carried on by an outside agency the assessee would still be considered as manufacturer. The coordinate Bench of the Tribunal has also taken identical view in case of Sunrise Metal Industries [2002 (11) TMI 248 - ITAT BOMBAY-H]. The Ld. D.R. for the Revenue has failed to bring on record if this settled proposition of law has been overturned by any higher forum. Appeal filed by the Revenue is hereby dismissed.
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