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2009 (12) TMI 575 - HC - Income TaxDisallowance of deduction - Assessee is a supportig manufacturer - The order of the Commissioner issued under section 263 of the Income-tax Act is confirmed by the Tribunal - Based on the Supreme Court in IPCA Laboratory v. Deputy CIT [2004 -TMI - 6141 - SUPREME Court] wherein the Supreme Court has clearly held that unless profit is derived by the exporters in respect of the export, the supporting manufacturer is not entitled to deduction based on the disclaimer certificate issued which in this case produced by the appellant shows that exports resulted in loss to the exporters Section 80-IA - The claim is not tenable because fish processing is not manufacture or production of an article as held by the Supreme Court in CIT v. Relish Foods [1999 -TMI - 5729 - SUPREME Court] - Appeal are dismissed
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