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2016 (2) TMI 197 - AT - Income TaxAssessment under Section 153 A - Eligibility of deduction u/s 80IB and 80IC denied - Held that:- None of the material seized during the search relates to the year under appeal.None of the material found relate to the goods transfer to one unit from other for the period. None of the material relates to the purchases from sister concerns.None of the material suggest that the material transferred to eligible undertaking is less than the market rate. None of the material suggest that the eligible units are not carrying out manufacturing activity, which is stated by assessee. None of the material shows that there is inflation of the profit by assessee of eligible undertakings. None of the material suggest that appropriation of profit made by the assessee to derive the income of eligible undertaking is incorrect. None of the material suggest that eligible units earns „more than Ordinary profits‟. In view of above, we confirm that the material found during the course of search is not incriminating which even remotely suggest that assessee's claim of deduction u/s 80IC/80 IB is incorrect. - Decided in favour of assessee
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