2013 (5) TMI 124

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..... in favor of assessee. - ITA (L) No.2131, 2133, 2134, 2135 of 2012 - - - Dated:- 7-3-2013 - J P Devadhar and M S Sanklecha, JJ. For the Appellant: Mr Suresh Kumar For the Respondent: Mr P J Pardiwala, Sr. Adv. A K Jasani JUDGEMEMT:- In all these appeals by the revenue following questions of law have been framed for our consideration. a) Whether on the facts and in the circu .....

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..... he basic dispute in these appeals is whether the activity of bottling LPG Gas amounts to production or manufacturing activity for the purpose of deduction under Section 80HHC, 80I and 80IA of the Income Tax Act, 1961. The Tribunal by the impugned order held that subject activity amounts to production/manufacturing for the purpose of Section 80HHC, 80I and 80IA of the Income Tax Act, 1961 by relyin .....

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..... Sales Tax Matter) where activity of bottling the gas was not considered as manufacturing activity under the Gujarat Sales Tax Act,1969. 4) Since the Tribunal in the impugned order has relied upon the decision of this Court and the consequent order of the Electricity Ombudsman to hold that the activity of bottling LPG Gas is a very specialized process and the same is considered to be an activity .....

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