TMI Blog2015 (9) TMI 1404X X X X Extracts X X X X X X X X Extracts X X X X ..... judicated this very substantial question in asssesee’s favour - Decided against revenue Sec. 80IB disallowance qua income from exchange rate difference - Held that:- We find that the hon’ble jurisdictional high court in CIT vs. Deversons Industries Ltd. [2015 (1) TMI 394 - GUJARAT HIGH COURT ] has considered hon’ble apex court decision in Liberty India vs. CIT (2009 (8) TMI 63 - SUPREME COURT) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1,98,072/- to be eligible for section 80IB deduction. Its case is that the same has no direct or immediate nexus with the manufacturing activity in question. 3. The assessee-firm manufactures various kinds of lubricants and greases. Its manufacturing is in Silvasa, Dadra Nagar and Haveli (UT). It is already eligible for section 80IB deduction. The Assessing Officer noticed impugned scrap sales ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s Juthabai Zaveri (2002) 258 ITR 785 (Guj) holding that scrap sales do have a direct nexus with manufacturing activity in question. 5. Heard both sides. Records perused. The Revenue s only argument is in tune with the Assessing Officer s findings narrated hereinabove that the impugned scrap sales cannot be held to have been derived from asssessee s manufacturing activity as per the tribunal s o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... against that of the learned coordinate bench and reject the Revenue s first substantive ground. 6. This leaves us with the Revenue s second substantive ground seeking to restore sec. 80IB disallowance qua income from exchange rate difference of ₹ 66,05,498/-. Its case is that the same does not have any direct or immediate nexus with the manufacturing activity in question. The Commissione ..... X X X X Extracts X X X X X X X X Extracts X X X X
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