TMI Blog2014 (11) TMI 811X X X X Extracts X X X X X X X X Extracts X X X X ..... in law in directing to allow deduction u/s80HHC on labour charges, since in assessee's case there was no direct nexus between labour charges receipt and export business of the assessee which can be termed as substantial question - Decided partly in favour of revenue. - Income Tax Appeal No. 1532 of 2012 - - - Dated:- 14-11-2014 - S. C. Dharmadhikari And A. A. Sayed,JJ. For the Appellant : ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the circumstances of the case and in law, the Ld.ITAT has erred in not upholding the action of the AO in invoking provisions of section 145(3) of the I.T.Act in view of the assessee's failure to produce requisite evidence to establish that the invoice rates were varying according to the quality of the marble sold. (3) On the facts and in the circumstances of the case and in law, the Ld.ITAT ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... labour charges receipt and export business of the assessee. (5) On the facts and in the circumstances of the case, the Ld.ITAT has erred in law in deleting the addition of ₹ 6,79,18,885/- relating to sales tax subsidy by accepting the assessee's claim that it was capital receipt and hence, exempt, by relying upon the decision of DCIT Vs. Reliance Industries in ITA No.4045/M/91, ignori ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the following substantial question of law, and which reads as under:- On the facts and in the circumstances of the case, the Ld.ITAT erred in law in directing to allow deduction u/s80HHC on labour charges though the facts of the assessee's case were distinguishable from those in the case of CIT vs. Bangalore Clothing Co., 260 ITR 371 (Bom.), since in assessee's case there was no direc ..... X X X X Extracts X X X X X X X X Extracts X X X X
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