TMI Blog2007 (12) TMI 218X X X X Extracts X X X X X X X X Extracts X X X X ..... business of the assessee included not only manufacturing but all incidental activities undertaken till the delivery of the manufactured goods was effected. The benefit of the deduction to the assessee in terms of section 80-IA of the Act cannot be denied since the receipts on account of transportation are a part of its business receipts - 1388 of 2006 and 705 of 2007 - - - Dated:- 4-12-2007 - MADAN B. LOKUR and DR. S. MURALIDHAR JJ. Prem Lata Bansal for the appellant. Bhakti Pasrija for the respondent. JUDGMENT 1. I. T. A. No. 1388 of 2006 is directed against an order dated March 31, 2006, passed by the Income-tax Appellate Tribunal, New Delhi Bench 'G" ("the Tribunal") in I. T. A. No. 492/Del/2001 for the assessment ye ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n RBI bonds 6,61,83,046 4. The assessee claimed a deduction under section 80HHB, inter alia, in respect of the interest on RBI bonds to the extent of Rs. 6,61,83,046. The assessee also claimed deduction under section 80-IA of the Act. The Assessing Officer declined the deduction on the ground that the interest on RBI bonds was not the income derived from the business activities of the assessee. Likewise, the Assessing Officer also disallowed the deduction under section 80-IA in relation to transportation charges of Rs. 54,92,85,651 which the assessee had received for transportation of certain sleepers made by it to the railway sites. The Assessing Officer noted that there was a separate agreement for transportation of sleepers ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... egards the deduction claimed under section 80-IA of the Act in respect of the transportation charges received by the assessee for transportation of sleepers to the railway sites, she submitted that since there was a separate agreement for this purpose, such income could not qualify for the purposes of such deduction. Ms. Bansal further submitted that as regards the connected appeal (I. T. A. No. 705 of 2007) in respect of the assessment year 2000-01 it stood on a different footing since the interest earned on RBI bonds was not relatable to the said assessment year. 7. We are unable to agree with the submissions advanced/made by learned counsel for the Revenue. We find that as regards the interest on RBI bonds, this was part of the total ..... X X X X Extracts X X X X X X X X Extracts X X X X
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