TMI Blog2014 (7) TMI 1260X X X X Extracts X X X X X X X X Extracts X X X X ..... e, Advocates for therespondent ORDER 1. Heard learned Counsel appearing on behalf of the respective parties. 2. The revenue, by these appeals, has raised the following substantial questions of law : "(a) Whether on the facts and circumstances of the case, the ITAT Panaji is correct in holding that the assessee is engaged in manufacturing activities ? (b) The ITAT, Panaji has not appreciate ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the earlier year by the revenue in assessee's case. The Tribunal also found that earlier the Assessing Officer had confirmed that the activity undertaken by the assessee qualifies to be a manufacturing activity. The Tribunal accordingly applied the principle of consistency and allowed the deduction under Section 80-IB of the Act. 5. The Division Bench of this Court in "CIT v. Arts & Crafts Ex ..... X X X X Extracts X X X X X X X X Extracts X X X X
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