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2004 (4) TMI 68 - HC - Income Tax"1. Whether, Tribunal was right in upholding that the assessee was eligible for deduction u/s 32A? - 2. Whether Tribunal was right in reversing the order of the Assessing Officer that the cranes were to be treated as transport vehicles and not plant and machinery eligible for deduction u/s 32A? - 3. Whether, Tribunal was right in reversing the order of the Assessing Officer that the assessee-company was not eligible for deduction u/s 80-I?" - In the facts and circumstances of the case, the act of cutting and polishing granite slabs before exporting them did not involve any process of manufacture or production to entitle the assessee to the benefit u/s 32A or 80-I. In view of the aforesaid conclusion, it is not necessary to consider as to whether the machinery purchased by the assessee was a transport vehicle or not. – Thus, three questions are decided in the negative, in favour of the Department and against the assessee.
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