TMI Blog2014 (7) TMI 1260X X X X Extracts X X X X X X X X Extracts X X X X ..... (12) TMI 338 - Bombay High Court] held that whether the decision of the Tribunal in the case of assessee for earlier year that the assessee was engaged in manufacturing activity and, therefore, entitled to deduction under Section 80-IB, had been accepted by the revenue and no argument was advanced to establish that the said decision of the Tribunal was erroneous, allowability of deduction under S ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e is engaged in manufacturing activities ? (b) The ITAT, Panaji has not appreciated the fact that the principle of res judicata is not applicable to Income Tax proceedings as held by the Supreme Court in the case of New Jehangir Vakil Mills Co. Ltd Vs. CIT (SC) 49 ITR 137 and also as held by Bombay High Court in the case of Kotak Mahindra Finance Ltd., Vs. DCIT (Bom) 265 ITR 114 ? 3. Learne ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ection 80-IB of the Act. 5. The Division Bench of this Court in CIT v. Arts Crafts Exports [2012] 22 taxmann.com 53 (Bom.) held that whether the decision of the Tribunal in the case of assessee for earlier year that the assessee was engaged in manufacturing activity and, therefore, entitled to deduction under Section 80-IB, had been accepted by the revenue and no argument was advanced to es ..... X X X X Extracts X X X X X X X X Extracts X X X X
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