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2012 (6) TMI 231 - AT - Income TaxRevision u/s 263 - Whether CIT erred in holding that the deduction u/s. 80IA/80IB is not allowable to the Appellant Company on the ground that the unit owned by the Appellant Company does not manufacture or produce any article or thing - assessee is engaged in the business of buying different types of tea from the market, blending them in different proportions and thereafter sells the tea in the market - assessee has claimed that it is an industrial undertaking engaged in manufacturing activity and entitled for deduction u/s. 80IA/80IB of the Act – Held that:- assessee is engaged in the "Processing" activity only and there is no manufacturing activity of any kind. action of the AO in allowing the assessee's claim is erroneous and also prejudicial to the interest of revenue because income has been subjected to excessive allowance by deduction u/s. 80IA/80IB of the Act. In the absence of any specific enquiries on processing vs manufacturing of the various product of tea by blending various tea. AO failed apply his mind on the issue. order of the CIT does not call for any interference. - appeal of the assessee is dismissed
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