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2017 (4) TMI 1556 - AT - Income TaxDisallowance of deduction u/s 80IC - manufacturing got done by outside parties - denial of deduction on sale of products to the extent of profits relating to manufacturing which was got done through outside parties - HELD THAT:- It is not essential for the assessee to carry out the entire manufacturing itself for the purpose of claiming deduction on the profits earned thereon and even if a part of activities were outsourced or for that matter, even if the whole manufacturing activities were outsourced but carried on under the supervision and control of the assessee, it would still tantamount to manufacturing activity being carried out by the assessee itself, making it eligible to claim deduction of profit earned thereon. The ITAT, thereafter applying the said legal proposition to the facts of the case as per which the assessee carried out all the processes involved in the manufacturing of S.S. Flats except one and the final product, in any case, was manufactured by the assessee itself and further that the process outsourced was as per its specification and requirement,held that in such circumstances, the only conclusion which could be drawn was that the product had been “manufactured”by the assessee. It was, therefore, held that in view of the same, there was no question of denying the assessee the benefit of deduction of its eligible profits under section 80IC Since the facts in the present case are identical to that in the case of M/s Jaiswal Metals Pvt. Ltd. [2017 (2) TMI 1498 - ITAT CHANDIGARH] the decision rendered therein squarely applies to the present case also, following which we hold that the assessee is entitled to deduction of its entire eligible profits u/s 80IC - The addition, therefore, made is directed to be deleted.- Decided in favour of assessee.
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