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2019 (8) TMI 522 - HC - Income TaxDeduction of certain amount u/s 80 IB/IC as part of trading profits for the bated unit - HELD THAT:- The record shows that the assessee derived this income from the sale of boxes manufactured by it to house electric meters. It is not disputed that the deduction under Section 80 IB/IC was for manufacture of electric meters. The manufacture and supply of boxes, which are essentially for housing electronics meters so as to make it convenient for use by the consumers is an activity intrinsically connected with the business qualifying for deduction. As a consequence, it is held that this question of law does not arise. Dis-allowance under Section 14 A - HELD THAT:- Decision of Godrej & Boyce Manufacturing company ltd. Vs. Deputy Commissioner of Income Tax & Anr. [2017 (5) TMI 403 - SUPREME COURT] covers the question of dis-allowance against the revenue under Section 14 A. ALP determination and adjustment, the question does not arise in view of the recent decision of this Court in Pr. Commissioner of Income Tax, Udaipur Vs. M/s Secure Meters Ltd., E-Class, Pratapnagar Industrial Area, Udaipur [ 2019 (8) TMI 512 - RAJASTHAN HIGH COURT ]. Adjustment on account of the corporate guarantee provided by the assessee to its A.E, does not arise. The reasoning is that such corporate guarantee is part of the commercial activity of the assessee and no cost was incurred by the assessee when it provided this benefit to its A.E. By all accounts it appears, therefore, to be book transaction. List the appeals for hearing on 03.09.2019.
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