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2024 (1) TMI 559 - HC - Income TaxEligibility of deductions u/s 80IC - no printing or manufacturing of books in the eligible undertaking at Rudrapur - as per AO assessee did not carry out any printing or binding of books in the eligible undertaking at Rudrapur as neither the paper nor the printed material reached the eligible unit for printing, cutting and binding etc. and no manufacturing activity had actually taken place, therefore, the deduction u/s 80IC not be allowed - according to assessee process of printing and binding of books is certainly carried out in the eligible undertaking of the respondent/assessee at Rudrapur - HELD THAT:- The question as to whether the exercise of printing and binding of books is carried out at the eligible undertaking of the respondent/assessee is a question of fact, on which findings of CIT(A) in favour of the respondent/assessee were confirmed by the Tribunal.There being no ground raised by the appellant/revenue alleging perversity in the said findings of facts, this court under Section 260A of the Act cannot venture into that aspect. TDS u/s 194H - trade discount offered by the assessee to the buyer - non deduction of TDS - HELD THAT:- The issue under Section 40(a)(ia) of the Act stands already covered in favour of the assessee by way of judgment of the Supreme Court in the case of Ahmedabad Stamp Vendors Association [2012 (9) TMI 298 - SC ORDER]
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