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The appeal was made by the assessee for deduction under section 80-I of the Income-tax Act, 1961. The Appellate Tribunal in Bangalore dismissed the appeal, stating that the assessee did not fulfill the condition of employing 10 or more workers in the manufacturing process, as required by the section. The Tribunal held that the workers employed by an agency of the assessee cannot be considered as the assessee's workers for the purpose of the deduction. The decision in the case of Kapri international (P.) Ltd. v. ITO [1984] 8 ITD 820 (Delhi) was cited but found not to support the assessee's contention.
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