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2016 (6) TMI 1185 - AT - Income TaxEligibilty for section 80IB deduction - Held that:- There is no quarrel about the fact that the assessee received the impugned purchase discount from raw materials/consumables suppliers to the tune of ₹ 2,99,153/- as utilized in its eligible business of manufacturing of specialty chemicals whose profits are already eligible for section 80IB deduction. Both the ld. lower authorities do not rebut assessee’s books specifically stating the crucial live nexus between the discounted raw materials and its manufactured specialty chemicals. Net effect thereof is that assessee’s eligible profits derived from its manufacturing activities have seen increased since raw material costs have come down due to the impugned discount forming integral part of the manufacturing process. We conclude that the authorities below have wrongly equated these facts with those involved in hon’ble apex court decision in Liberty India vs. CIT (2009 (8) TMI 63 - SUPREME COURT ) involving DEPB sales figures. We accept assessee’s contentions on merits and reject those raised at Revenue’s behest supporting the impugned disallowance.
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