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TMI Blog2018 (5) TMI 155X X X X Extracts X X X X X X X X Extracts X X X X ..... RDER ( Judgment of the Court was delivered by T. S. Sivagnanam, J. ) Heard Mr.T.Ravikumar, learned counsel for the Revenue and Mr.R.Sivaraman, learned counsel for the assessee. 2. This appeal, filed by the Revenue, is directed against the order passed in I.T.A.No.807/Mds/2002 dated 23.06.2006, on the file of the Income Tax Appellate Tribunal, Madras B Bench, Chennai, for the assessment year 199 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e said figure, the assessing officer granted deduction under Section 80HHC of the Act. 5. The assessee filed an appeal before the Commissioner of Income Tax (Appeals)-V in ITA No.469/2001-02. The first appellate authority, by order dated 07.02.2002, allowed the assessee's appeal on the said aspect and held that the income earned by the assessee from the job work of machining has to be conside ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ppeal as against the said judgment by way of this tax case appeal. 8. The undisputed fact is that the assessee is not carrying on machining activity as its main line of business. This fact has been admitted by the Commissioner of Income Tax (Appeals) as well as before the Tribunal. The activity of machining done by the assessee is when the machinery, which is used for manufacturing activities for ..... X X X X Extracts X X X X X X X X Extracts X X X X
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