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TMI Blog2017 (4) TMI 616X X X X Extracts X X X X X X X X Extracts X X X X ..... ER The Revenue is aggrieved by the ITAT's decision which remitted the matter to the Assessing Officer to consider the relevant facts for the periods in question and render specific findings having regard to the objective material as to the proportion, if any, of manufacturing and construction undertaken by the assessee, as a part of its track laying and construction activities for which it claime ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n integral part of entire activity and namely for the reason that such an activity was not very significant compared to total turnover of the assessee it could not be said the assessee not engaged in manufacturing activity. In the provision of 80HH of the Act, as noted above, it is mandated that where the total gross income of an assessee includes any profits and gains derived from an industrial u ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... placed on record. He further submitted that if opportunity is allowed then the calculation in regard to income from manufacturing activities may be placed before the competent authority to discharge onus cast upon the assessee to substantiate its claim of deduction. The Ld. CIT (DR) has objected to above submissions of assessee by contending that when there is not separate accounts then and detai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... uction and thus we find it appropriate to send the issue for limited purposes i.e. for calculation of deduction u/s 80HH on the income earned from manufacturing activities during the relevant periods under consideration for all five assessment years. Hence, we direct the AO to calculate the quantum of deduction for all the five assessment years under consideration." This Court is of the opinion ..... X X X X Extracts X X X X X X X X Extracts X X X X
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