TMI Blog2008 (12) TMI 370X X X X Extracts X X X X X X X X Extracts X X X X ..... ch was partly allowed by the Assessing Officer. On appeal, the Commissioner of Income-tax (Appeals) upheld the plea of the assessee, which has been affirmed by the Tribunal. Held that- it was not the case of the revenue that the business of the assessee did not fall under sub-section (3) to (11), (11A) or (11B) of the Ac. The assessee was at liberty to do manufacture for itself or for others, whic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essing activities as processing activities do not constitute manufacture of a product ?" 2. The assessee is engaged in manufacturing and trading of tractor and auto parts and also doing job work of similar nature. It claimed deduction under section 80-IB of the Act on income from job work, which was partly allowed by the Assessing Officer. On appeal, the Commissioner of Income-tax (Appeals) uphe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee is at liberty to do manufacture for itself or for others, which makes no difference for purposes of section 80-IB of the Act. The Tribunal has also relied upon similar view taken by the Delhi High Court in CIT v. Northern Aromatics Limited [2005] 196 CTR 479. 6. Since the view taken by the Tribunal is clearly supported by the bare language of the statute, we are unable to hold that any ..... X X X X Extracts X X X X X X X X Extracts X X X X
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