TMI Blog2015 (3) TMI 219X X X X Extracts X X X X X X X X Extracts X X X X ..... nts which are disassembled for exports. Considering these facts, the Tribunal affirmed the Ld. CIT(A)’s order. We find that the aforesaid decision of the Tribunal is also applicable in this assessment year - Decided against Revenue. - ITA No.5145/Del/2013 - - - Dated:- 14-3-2014 - R P Tolani And Shamim Yahya, JJ. For the Appellant : Ms Y Kakkar, Sr. DR For the Respondents : Shri Ashwa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ring activity is being conducted at the premises located at NSEZ Noida. (c) In ignoring the ground that design and development activities claimed to have been carried out by the assessee were done at a design cell located at non SEZ unit, not eligible for deduction u/s. 10B of the Act. (d) In not appreciating the erection and commissioning income of ₹ 23,18,760/- related to the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the present assessment year. 4. We have carefully considered heard the submissions and perused the records. We find that consequent upon the AO s rejection of the claim u/s. 10B by the assessee, Ld. CIT(A) has decided the issue in favor of the assessee by holding as under:- I have carefully considered the submissions of the Ld. AR for the appellant, order of the AO for the year under a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hich were erected and commissioned abroad. The appellant company manufacturers various components and subassemblies for the ultimate finished product of cement mill and steel rolling plants and this is no less than any manufacturing of goods / things as contemplated u/s. 10B of the Act. Respectfully following the judgement of the ITAT for A.Y. 2007-08 and 2008-09 in assessee s own case when there ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... unt of ₹ 20,83,365/-. 5. We find that the Tribunal in the aforesaid order as referred by the Ld. CIT(A) has elaborate referred to the facts and circumstances of the case and has concluded that assessee was engaged in the manufacturing of assembling the plants which are disassembled for exports. Considering these facts, the Tribunal affirmed the Ld. CIT(A) s order. We find that the afores ..... X X X X Extracts X X X X X X X X Extracts X X X X
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