9911796707
TMI Blog2013 (5) TMI 956X X X X Extracts X X X X X X X X Extracts X X X X ..... Associates for the appellant. Mr. Suresh Kumar for the respondent. ORDER The common substantial question on which both these appeals were admitted on 24 November 2008 is as under:- "i) Whether on the facts and circumstances of the case, the Tribunal erred in law in holding that Appellant was not entitled to deduction under Sections 80HH and 80I/80IA of the Income Tax Act, 1961 in respect o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n 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 of manufacture. The Tribunal in the impugned order had observed to the effect that the word used in Section 80HH, 80I/80IA of the Act is manufacturing or production. The term production is wider than the word ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Revenue does not dispute that the questions raised in these appeals are covered by the decision dated 7 March 2013. 3. Following the aforesaid decisions, we allow these appeals and answer the questions as under:- Question No.1 in each appeal is answered in the negative i.e. in favour of the assessee and against the Revenue. Question No.2 in each appeal following the aforesaid answer is al ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
