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2017 (4) TMI 616 - HC - Income TaxBenefit of Section 80HH - Held that:- It was the duty and onus on the shoulder of the assessee to show that he was also engaged in manufacturing activities and the gross total income declared by it also include income from manufacturing activity and on the basis of foregoing discussion we have held that the assessee is entitled for deduction u/s 80HH and 80I of the Act on the part of income earned from manufacturing activities. However, for want of adequate material on the record of the Tribunal, it is not possible for us to calculate quantum of deduction and thus we find it appropriate to send the issue for limited purposes i.e. for calculation of deduction u/s 80HH on the income earned from manufacturing activities during the relevant periods under consideration for all five assessment years. This Court is of the opinion that the pointed and specific nature of the directions of the ITAT was sufficient to allay any doubt of the Revenue as to the nature of the remit which the Assessing Officer is expected to address himself to. In the circumstances, no substantial question of law arises
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