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TMI Blog2015 (10) TMI 1425X X X X Extracts X X X X X X X X Extracts X X X X ..... l purchased by the assessee, CIT(A) was justified in holding that the activity carried out by the assessee definitely falls under the definition of manufacture and therefore was entitled to the deduction. In this view of the matter, we confirm the order of the CIT(A) and ground of appeal of the revenue is dismissed. - Decided in favour of assessee. - ITA No. 6290/Del/2012 - - - Dated:- 2-6-2015 - ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Act. He submitted that the assessee was not in the business of manufacturing or producing any article or thing. He relied on the order of the AO. Ld. Counsel for the assessee submitted that the assessee was in the business of design and provide in customized software and electronic hardware for industrial use and therefore was eligible for deduction u/s 80-IC (2) (a) (ii) of the Act. He submi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... We find that the assessee was engaged in the business of manufacturing and sale of customized electronics parts alongwith software and for sale. The huge hardware and software were designed according to the needs of the customers. The CIT(A) has given a finding that the assessee after designing the required software and hardware installed the same in the premises of its customers and also trains t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he final product was manufactured after using different hardware and software and the finished product being different from the raw material purchased by the assessee, CIT(A) was justified in holding that the activity carried out by the assessee definitely falls under the definition of manufacture and therefore was entitled to the deduction. In this view of the matter, we confirm the order of the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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