TMI Blog2012 (3) TMI 548X X X X Extracts X X X X X X X X Extracts X X X X ..... of a notice dated 28 March 2007 by which an assessment for Assessment Year 200001 is sought to be reopened under Section 148 of the Income Tax Act, 1961. The grounds on which the assessment is sought to be reopened are as follows: During the scrutiny proceedings for A.Y. 200405, deduction u/s. 80IA has been withdrawn stating that the activity of making perfumed hair oil by merely blending a f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rse of the scrutiny proceedings for Assessment Year 200405. For Assessment Year 200405, the Income Tax Appellate Tribunal, however, held in favour of the Assessee by coming to the conclusion that the Assessee was engaged in manufacturing activity of production of Perfumed Hair Oil and that in the case of the Assessee itself, for the first Assessment Year 199899 a deduction under Section 80IB had b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... distinct from the inputs used and on the said manufactured product the Central Excise duty has been paid. The Apex Court in the case of Commissioner of Central Excise, Surat v/s Zandu Pharmaceutical Works Ltd., reported in (2006) 12 SCC 453 has held that addition of perfume to coconut oil to produce perfumed oil constitutes a manufacturing process. Moreover in the present case it is not in disput ..... X X X X Extracts X X X X X X X X Extracts X X X X
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