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TMI Blog2020 (11) TMI 881X X X X Extracts X X X X X X X X Extracts X X X X ..... /tax holding u/s 80HH/80I and 80IA of the Act on lean gas at the stage of customer terminals. - ITA No. 5775/Del/2014 ITA No. 5912/Del/2014 - - - Dated:- 26-11-2020 - SHRI N.K. BILLAIYA, ACCOUNTANT MEMBER And MS. MADHUMITA ROY, JUDICIAL MEMBER Assessee by : Shri Rohit Jain, Advocate Ms. Deepashree Rao, CA Shri Vibhu Gupta, CA Department by : Ms. Sunita Singh, CIT(DR) ORDER ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... terminals, as claimed by the appellant following the order of CIT (A) for the preceding assessment year. 1.1That on facts and circumstances of the case and in law, the CIT(A) erred in holding that the activities undertaken by the appellant at its customer terminals did not constitute manufacture or production of any article or thing , so as to be eligible for deduction under sections 801, 8 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or production of any article or thing . 1.4 That on the facts and circumstances of the case and in law, the CIT(A) erred in holding that the AO had not allowed the deductions under section 801, 801A in the initial assessment year 1992-93. 3. The issues raised vide ground No. 1 to 1.4 are identical to the issues considered by the Tribunal in assessee s own case in the previous assessment ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... deduction after allowing the applicable expenses. 3. On the facts and circumstances of the case and in law, Ld. CIT(A) has erred in allowing the claim of horticulture expenses amounting to ₹ 1,23,80,000/- as revenue expenditure. 4. On the facts and circumstances of the case and in law, Ld.CIT(A) has erred in directing the Assessing Officer to allow the investment allowance u/s 32 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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