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TMI Blog2019 (8) TMI 522X X X X Extracts X X X X X X X X Extracts X X X X ..... ion 80 IB/IC was for manufacture of electric meters. The manufacture and supply of boxes, which are essentially for housing electronics meters so as to make it convenient for use by the consumers is an activity intrinsically connected with the business qualifying for deduction. As a consequence, it is held that this question of law does not arise. Dis-allowance under Section 14 A - HELD THAT: ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... appears, therefore, to be book transaction. List the appeals for hearing on 03.09.2019. - D.B. Income Tax Appeal No. 81/2017, 10, 11/2013, 118/2014, 74, 92, 93/2017 - - - Dated:- 7-8-2019 - S. Ravindra Bhat And Mr. Vinit Kumar Mathur, JJ. For Appellant(s): Mr.K.K.Bissa Mr.G.S.Chouhan For Respondent(s): Mr.Anjay Kothari Order 1. Admit. 2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f different eligible industrial undertaking for computing deduction u/s 80IB / 80IC? 3. Mr.Anjay Kothari accepts notice on behalf of the respondents. 4. The other questions of law urged are first with respect to justifiability of deduction of certain amount under Section 80 IB/IC as part of trading profits for the bated unit. The second question is with respect to deletion of ap ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (SC) covers the question of dis-allowance against the revenue under Section 14 A. As regards the ALP determination and adjustment, the question does not arise in view of the recent decision of this Court in Pr. Commissioner of Income Tax, Udaipur Vs. M/s Secure Meters Ltd., E-Class, Pratapnagar Industrial Area, Udaipur [D.B.I.T.Appeal 139/2018 decided on 29.07.2019]. 6. As far as the ques ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at in I.T.Appeal No.74/2017, the additional question urged i.e. adjustment on account of the corporate guarantee provided by the assessee to its A.E, does not arise. The reasoning is that such corporate guarantee is part of the commercial activity of the assessee and no cost was incurred by the assessee when it provided this benefit to its A.E. By all accounts it appears, therefore, to be book tra ..... X X X X Extracts X X X X X X X X Extracts X X X X
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