TMI Blog1988 (12) TMI 85X X X X Extracts X X X X X X X X Extracts X X X X ..... the instance of the Revenue, reads thus : "Whether, on the facts and in the circumstances of the case, the assessee-company can be treated as one engaged in a priority industry and whether deduction under section 80-I of the Income-tax Act, 1961, and development rebate at higher rate are admissible ?" The issue to be considered is whether the assessee manufactures or produces one or more of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... communication equipment fell, according to him, outside item (17) of the Sixth Schedule. The said item (17) dealt with "electronic equipment, namely, . . . electronic communication equipment . . .". The assessee preferred an appeal to the Income-tax Appellate Tribunal and produced an opinion obtained from the Technical Director of the Department of Electronics, Government of India, which stated th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... erence to external aids in interpretation may be resorted to only if there is an ambiguity. There being no ambiguity here and , reference cannot be made to the provisions of the Industries (Development and Regulation) Act or, for that matter to anything else. It is relevant also to note, as the Tribunal did, that where the Legislature intended recourse to be taken to the Industries (Development an ..... X X X X Extracts X X X X X X X X Extracts X X X X
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