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Issues involved: Claim of deduction u/s 80IB of the Income Tax Act for manufacturing activity.
Summary: The Revenue appealed against the Tribunal's judgment regarding the deduction of Rs. 46,05,565 under section 80IB of the Income Tax Act, contending that the activity carried out by the assessee did not amount to manufacturing. The Tribunal allowed the deduction based on the creation of a new product, NPK mix, and the principle of consistency in granting benefits. The High Court, after reviewing the case, found no substantial question of law and upheld the Tribunal's decision, emphasizing that the activity qualified as manufacturing and benefits were granted in previous years without issue. The tax appeal was consequently dismissed.
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