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TMI Blog2015 (11) TMI 1001X X X X Extracts X X X X X X X X Extracts X X X X ..... hat:- A s held by Tribunal, being final fact finding authorities, find no force in the submissions of the Ld. DR that documents were not filed before the Assessing Officer. The reading of the assessment order for assessment year 2006-07 clearly show that documents were filed before the Assessing Officer also. - Decided in favour of assessee. - Income Tax Appeal No. 11 of 2014 - - - Dated:- 6-10-2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed by the assessee, with respect to which they claimed statutory exemption, under the provisions of Section 80IC(4)(ii) and Explanation-1 of sub-section (3) of Section 80IA of the Income Tax Act, 1961 (hereinafter referred to as the Act), which the Assessing Officer disallowed. 3. In an appeal filed by the assessee, order passed by the Assessing Officer stood reversed. Even the Tribunal, vide i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ions of Explanations 1 and 2 to sub-section (3) of section 80-IA shall apply for the purposes of clause (ii) of this sub-section as they apply for the purposes of clause (ii) of that sub-section. 5. Explanation-1 of sub section (3) of Section 80IA of the Act, reads as under: Explanation 1.-For the purposes of clause (ii), any machinery or plant which was used outside India by any person ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the submissions of the Ld. DR that documents were not filed before the Assessing Officer. The reading of the assessment order for assessment year 2006-07 clearly show that documents were filed before the Assessing Officer also. In these circumstances, we find nothing wrong with the order of Ld. CIT(A) and confirm the same. 8. Such findings of fact, by no means, can be said to be perverse or n ..... X X X X Extracts X X X X X X X X Extracts X X X X
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