TMI Blog2017 (5) TMI 1641X X X X Extracts X X X X X X X X Extracts X X X X ..... d that:- Appellant has relied upon the decision of Commissioner of Income Tax vs. Mandideep Eng. & PKG. India (P) Ltd. [2006 (4) TMI 75 - SUPREME COURT] wherein held as - "Section 80HH and 80-I are independent of each other and therefore a new industrial unit can claim deduction under both the sections on the gross total income independently." The respondent has pointed out that the same matter ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... original return of income claiming deduction u/s 80IB and 80HHC of the Act was filed on 30.10.2001. Subsequently the reassessment proceeding were initiated and the case of the appellant was reopened u/s 147/148 of the Act. 2.1 The appellant claimed the deduction simultaneously u/s 80HHC and 80IB of the Act, on the profit of business eligible for deduction. The Assessing Officer disallowed the s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 8377; 33,595/- on account of interest on FDR from the business income of the appellant for the purpose of computation of deduction u/s 80IB of the Act, on the ground that the direct nexus between the income and industrial undertaking has not been established. 3. This court while admitting the appeal on 9.5.2017 framed following substantial question of law:- whether Section 80HHC and 80IB o ..... X X X X Extracts X X X X X X X X Extracts X X X X
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