TMI Blog2007 (6) TMI 190X X X X Extracts X X X X X X X X Extracts X X X X ..... apparatus - Tribunal also found that the job work is linked to the manufacturing – hence Tribunal is right in holding that 90% of the job work charges should not have been excluded from business profits while computing deduction u/s 80HHC - 293 of 2004 - - - Dated:- 18-6-2007 - COMMISSIONER OF INCOME-TAX Versus UNITED INDIA SHOE CORPORATION P. LTD. (formerly known as United India Shoe Corp ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... uded from such business profits from computing the deduction u/s.80HHC?" 2. The assessee firm is engaged in the business of manufacture and export of shoe uppers. The assessment of the assessee firm for the assessment year 1996-97 was originally completed under Section 143(3) of the Income Tax Act (for brevity, "the Act") on 13.8.1997. The Assessing Officer, subsequently, found that the assess ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sessing Officer to work out the deduction under Section 80HHC of the Act. 4. The Tribunal, in the further appeal preferred by the assessee, accepted the contention of the assessee that 90% of the job work charges should not have been excluded while computing the deduction under Section 80HHC of the Act and allowed the appeal of the assessee. Hence, the present appeal. 5. Mrs.Pushya Sitara ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... it is not in dispute that the income from job work earned by the assessee is by utilisation of the entire resources or business apparatus. The Tribunal had also found that the job work is linked to the manufacturing activity of the assessee. If that be so, we find no error or infirmity in the order of the Tribunal holding that 90% of the job work charges should not have been excluded from business ..... X X X X Extracts X X X X X X X X Extracts X X X X
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