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2015 (2) TMI 1101 - AT - Income TaxEligibility for deduction u/s 80-IC - Held that:- The entire work was executed in conformity with technical details provided through detailed fabrication drawings of the client. The appellant had produced copies of excise returns filed, bills of purchase of machinery and raw material, and details of job work paid. The firm was found to be registered with VAT, CST, Service tax and Central Excise Authorities. Reliance was placed on the judgement of the Delhi High Court in the case of CIT vs Northern Aromatics Ltd (2005 (2) TMI 830 - DELHI HIGH COURT ) to hold that the activity of the appellant had to be regarded as manufacture irrespective of whether the products manufactured are for its own business or as job work for others. After considering the evidence furnished of fabrication and assembly of trusses, columns, gantries, etc. for the steel plant of M/s Dharmpal Premchand Ltd., it was held that the appellant was entitled to the deduction under section 80le. No new facts have been brought on record in the current year to disprove the appellant's claim. It is held accordingly that the appellant is engaged in the 'manufacture' of articles and is therefore, eligible for the deduction under section 80IC. - Decided in favour of assessee.
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