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2018 (8) TMI 729 - HC - Income TaxDeduction u/s 80IB - manufacturing activity or not of electronics computer - whether the term manufacturer under Section 80 IB would include manufacturing activity being carried out outsourced to another party - Held that:- the assessee could not even produce the primary evidence in the shape of books of accounts, resolutions, even to suggest that it had deployed its manpower at the factory premises of M/s. Kobian ECS India Pvt. Ltd. and had retained the control over the manufacturing activity. The Appellants could not produce particulars like attendance register, qualifications of the employees in spite of being asked to do so by the Assessing Officer. - In fact, it appears even the packaging material was supplied to contract manufacturer by the Appellants-Company for finished products at Silvassa. Appellants were not carrying out manufacturing activity of electronic computer products within the meaning of Section 80 IB of the Act - Deduction u/s 80IB not allowed - Decided against the assessee.
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