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TMI Blog2014 (3) TMI 31X X X X Extracts X X X X X X X X Extracts X X X X ..... thing and has been executed as a single integral work order - It is technically also a project as it includes man, job design, control system design and design of a method of employing specific technology to do the work - Entire consideration is attributable to such execution of the projects - The AO is satisfied with other requirements for eligibility for entitlement to deduction u/s 80HHB of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rder dated 10th June, 2003 by which the learned Tribunal disallowed deduction under Section 80HHB of the Income Tax Act on the ground that the assessee could not file any evidence or document to show that there was any kind of project/contract with any foreign company except that he was engaged in supplying labourer on a particular project. Mr. Biswas, learned advocate appearing for the appella ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... es, the equipment and technicians are carefully selected and got approved, the project is executed with high degree of know how, vigilant supervision and monitoring maintenance of highest quality, efficiency, cost and time schedules is ensured. The workmen and the work executed have to be approved by International Agencies and certificate of seaworthiness of the vessel has to be obtained at every ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ranted deduction for Rs.4,32,346 and the disallowance of claim u/s.80HHB is deleted. Mr. Biswas submitted that the learned Tribunal in exercise of appellate power was duty bound to demonstrate infirmity in the finding recorded by the CIT (A), which the learned Tribunal did not do. The Tribunal by a cryptic order has disallowed the benefit capriciously rather than on the basis of any reason. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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