TMI Blog1997 (12) TMI 670X X X X Extracts X X X X X X X X Extracts X X X X ..... ns are proposed by the Revenue, as questions of law arising from the order of the Tribunal. 1. Whether, the Appellate Tribunal is right in law and on facts in confirming the view of the Commissioner of Income Tax (Appeals) to the effect that the amounts with regard to kasar, sale of empty soda ash bardans should include for working out the claim under Section 80I? 2. Whether, the Ap ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... found from the material on record that the tank rent and truck rent had no direct connection with the manufacturing activities and cannot be considered for relief. It was however, found that the items of kasar and sale of empty soda ash bardans, was directly connected with the manufacturing activities of the assessee and should be allowed. These are obviously findings of fact and when the T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessee was following mercantile system of accounting. The CIT (Appeals) had decided a similar point in Kodidas Patel's case and the Assessing Officer was directed to follow that decision in the present case also. It would appear that in view of the assessee following mercantile system of accounting, these directions were given in consonance with the earlier decision. It is brought ..... X X X X Extracts X X X X X X X X Extracts X X X X
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