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2018 (10) TMI 1594 - AT - Income TaxDeduction u/s. 80IB - CIT-A holding Unit No.47 as new Industrial Undertaking and allowing the deduction - industrial undertaking has more than one physical place for it’s allied activities - Held that:- The mere fact that an industrial undertaking has more than one physical place for it’s allied activities, such as storage of raw material, final touches and packing of end products or other ancillary activities would not mean that all these physical places are to be treated as standalone unit and profits for each of these places are to be computed separately. As learned CIT(A) rightly puts it, for setting up of new industrial undertaking, the number of building is wholly irrelevant. As all these units together constituted separate and distinct industrial undertaking eligible for deduction under section 80IB. We have also noted that there is no dispute that, vide registration dated 3rd June 2001, District Industries Centre has confirmed setting up of unit at “No.47 New Grain Market, Opp. Anupam Talkies, Khokhra, Ahmedabad” for production of “Readymade garments for children”. As for the statement made by the partners of the assessee firm, all that has been stated in the said statement is that the activities are carried out at other places as well but then none of these activities were independent activities on standalone basis or resulted in a distinct product. In any event, as is the settled legal position, statement recorded under section 131 has no evidentiary value, and there is nothing more than the statement which is put against the assessee in the present case. - Decided against revenue
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