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2007 (10) TMI 298 - DELHI HIGH COURTSpecial deductions under section 80HH and 80-I – As regards the question whether profits and gains from the sale of imported spare parts used in providing after sales service to customers would qualify for deduction, we are in agreement with the conclusions arrived at by the Tribunal that this activity might be incidental to the business activity of the assessee but that it has no direct nexus with the activity of the industrial undertaking which is the manufacture of gensets. The Tribunal was, in our opinion, right in concluding that profits and gains from such activity cannot be held to be “derived from the industrial undertaking”. – Hence profits from such sale were not entitled to special deduction
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