9911796707
TMI Blog2022 (3) TMI 616X X X X Extracts X X X X X X X X Extracts X X X X ..... of motor vehicle parts. Assessee electronically filed its return of income for A.Y. 2013-14 on 29.09.2013 declaring Nil income after claiming deduction of Rs. 3,21,71,012/- u/s 80IC of the Act. The case was selected for scrutiny and thereafter assessment was framed u/s 143(3) of the Act vide order dated 21.03.2013 and the total income was determined at Rs. 3,22,15,310/- by denying the claim of deduction u/s 80IC of the Act. Aggrieved by the order of AO, assessee carried the matter before the CIT(A) who vide order dated 08.03.2018 in Appeal No.10029/CIT(A)/HLD/2016-17 allowed the appeal of the assessee. Aggrieved by the order of CIT(A), Revenue is now in appeal and has raised the following grounds: 1. "That the Ld.CIT(A), Haldwani has err ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... deduction of Rs. 3,21,71,012/- u/s 80IC of the Act. He on perusing the details of purchase of raw material and sale of final product noted that the name of the goods purchase and goods sold were same. The assessee was asked to furnish and explain that as to what was the raw materials purchased, what process has been done on those raw materials and what was sold as final product. The assessee was also asked to justify in what way the company is manufacturing a new product. The submissions were made by the assessee but the same were not found acceptable to AO as he noticed that only drilling, turning and boring related works was done on the material in order to convert it as saleable item and which according to AO was part of job work and no ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... AO. 9. Learned AR on the other hand reiterated the submissions made before the lower authorities and supported the order of CIT(A). He further submitted that identical issue arose in assessee's own case in A.Y. 2009-10 and 2010-11 wherein the claim of deduction u/s 80IC of the Act was denied by the AO. When assessee carried the matter before CIT(A), CIT(A) decided the issue in favour of the assessee. He submitted that against the order of CIT(A), Revenue carried the matter before the Hon'ble Tribunal and the Tribunal in ITA No.5787/Del/2012 for A.Y. 2009-10 and ITA No.4521/Del/2013 for A.Y. 2010-11 vide order date 16.08.2017 decided the issue in favour of the assessee by upholding the order of CIT(A). He therefore submitted that in the abs ..... X X X X Extracts X X X X X X X X Extracts X X X X
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