TMI Blog2018 (3) TMI 221X X X X Extracts X X X X X X X X Extracts X X X X ..... uctions under section 80-IC of the Act Tribunal found that the issue of deduction claimed by the assessee has already been decided in the case of CIT v. Impel Forge and Allied Industries Ltd. [2008 (12) TMI 370 - PUNJAB & HARYANA HIGH COURT] and it held that for claiming deductions under the aforesaid provisions the assessee was at liberty to manufacture for itself or for others and the same do ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... oviding labour employment and factory space for the purpose of manufacture of medicines by various manufacturers and claimed deductions under section 1. 80-IC of the Act and the learned Tribunal found that the issue of deduction claimed by the assessee has already been decided by the Punjab and Haryana High Court in the case of CIT v. Impel Forge and Allied Industries Ltd. [2010] 326 ITR 27 (P ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 99 (Bom) and it was claimed that in this decision, it was held that sale of finished goods on the basis of specifications of third party was contract of sale and not works contract as contract between the two parties was on principal to principal basis. 2. In our considered view, the aforesaid finding recorded by the Tribunal in both cases are based on due appreciation of factual material ava ..... X X X X Extracts X X X X X X X X Extracts X X X X
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