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ITO, Ward 12 (3) New Delhi Versus M/s GVC Systems (P) Ltd

2015 (10) TMI 1425 - ITAT DELHI

Disallowance of deduction u/s 80IC(2)a(ii) - CIT(A) allowed the claim - Held that:- Since input and output of the assessee was entirely different products and the final product was manufactured after using different hardware and software and the fini .....

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on. In this view of the matter, we confirm the order of the CIT(A) and ground of appeal of the revenue is dismissed. - Decided in favour of assessee. - ITA No. 6290/Del/2012 - Dated:- 2-6-2015 - G C Gupta, VP And T S Kapoor, AM,JJ. For the Appellant .....

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e revenue is as under :- 1. "The Ld. CIT(A) has erred on facts and in law in deleting the disallowance made by the AO on account of assessee s claim of deduction u/s 80IC(2)a(ii) at ₹ 10,45,816/-." 2. Ld. DR submitted that the busines .....

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t the assessee was not in the business of manufacturing or producing any article or thing. He relied on the order of the AO. Ld. Counsel for the assessee submitted that the assessee was in the business of design and provide in customized software and .....

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sel for the assessee submitted that the end product is different and the purchases and sales are altogether different and that the hardware and software were being designed according to the needs of the customers. The same were installed in the premi .....

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that the activity of the assessee falls under the definition of manufacture. 3. We have considered the rival submissions and have perused the order of the AO and CIT(A). We find that the assessee was engaged in the business of manufacturing and sale .....

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e installed the same in the premises of its customers and also trains them regarding the huge hardware and software which has been installed. The CIT(A) has further recorded that the assessee was purchasing raw material in the form of PCB, integrated .....

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