TMI Blog2011 (4) TMI 846X X X X Extracts X X X X X X X X Extracts X X X X ..... They are the types of income which has no bearing insofar as the manufacturing activity of the assessee is concerned or the income derived from such manufacturing activity - However, the assessee has earned these receipts from job work utilizing the very same machinery and men and as a part of his manufacturing activity - Therefore, there is a direct nexus between the job work and the manufacturin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e appellate authorities were right in granting relief to the assessee and the same is in conformity with Explanation (baa) to section 80HHC of the Income-tax Act, 1961?" 3. The assessee is engaged in the manufacture and export of ready made garments. There was some receipts of Rs. 33,12,545 from job work charges which was part of the business activity of the assessee. Therefore, the same was inc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e of the said export business, utilizing some men and machinery, they have undertaken some job work and they have received the aforesaid amount of Rs. 33,12,545 as a part of the business activity of the assessee viz., manufacture and export of ready made garments. Explanation (baa) refers to receipts by way of brokerage, commission, interest, rent, charges or any other receipt of a similar nature ..... X X X X Extracts X X X X X X X X Extracts X X X X
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