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2015 (12) TMI 293 - AT - Income TaxRejection of claim for deduction u/s 10B - tax authorities have come to the conclusion that the assessee has not carried on any manufacturing activity - Held that:- The assessee has imported diamonds, purchased gold locally and exported the jewellery. Thus, the articles purchased and the articles exported are two different articles. The export of jewellery cannot be carried out without manufacturing the same. The assessee has also explained about its manufacturing process. Even though the conversion of gold into mountings is carried out through outsourcing, final shaping of jewellery and fitting of diamonds were carried out at the place of the assessee. Hence, in our view, the activities carried on by the assessee should be considered as manufacturing activity only and hence it is eligible to claim deduction u/s 10B of the Act.- Decided in favour of assessee.
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