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2015 (10) TMI 1425 - ITAT DELHI

2015 (10) TMI 1425 - ITAT DELHI - TMI - 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 finished product being different from the raw material purchased by the assessee, CIT(A) was justified in holding that the activity carried out by the assessee definitely falls under the definition of manufacture a .....

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CIT(A). The only ground of appeal of the 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 business of assessee is to design and provide software and electronic hardware for industrial use. He submitted that the business of providing training and designing do not cover under the provision of section 80-IC ( .....

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usiness of customized software. Ld. Counsel 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 premises of the customer and also trains them regarding the huge hardware and software which has been installed. He referred to the relevant portion of the order of the CIT(A) wherein detailed reasons were given by .....

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