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2016 (5) TMI 1405 - AT - Income TaxDeduction under Section 80IB - denial of claim on the ground that the activity of filling the gas into the cylinders does not constitute manufacturing and the LPG bottling Plants are part of the refining activities and cannot be considered as independent industrial undertakings - Held that:- The assessee's are entitled for deduction under section 80IA in respect of filing of LPG bottling Plants. See COMMISSIONER OF INCOME TAX-1 Versus M/s HINDUSTAN PETROLEUM CORPORATION LTD. [2013 (5) TMI 124 - BOMBAY HIGH COURT] Allowable deduction under section 80IA - claim for C3 and C4 plants in respect of Special Cut Naptha (SCN) plant - Held that:- We find that the year of commission of C3 & C4 SCN plant is 1991-92. This is the 10th year claim of deduction. In the earlier year, the revenue has allowed the deduction based on profit formula by taking the cost of the project into the business profit into percentage specified u/s 80IA of the Act upon Opening gross block of the corporation. The assessee has also given working of the computation of deduction on the basis of the same formula. Once on a particular formula, a deduction has been allowed then same should have been uniformly followed for the last year also. Accordingly, we direct the AO to examine the working of the assessee corporation and work out the allowable deduction under section 80IA to the assessee
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