TMI Blog2009 (9) TMI 21X X X X Extracts X X X X X X X X Extracts X X X X ..... see is supposed to explain that the end product, if any, is commercially known differently. However, in the present appeal the assessee even has not explained what is manufactured by it or whether the assessee is actually manufacturing anything, therefore, in the absence of all these facts, the benefit of deduction cannot be extended to the assessee - 468 of 2009 (O&M) - - - Dated:- 10-9-2009 - ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the learned ITAT is right in law in coming to the conclusion that the process of manufacturing rubber latex solution (adhesive) from the natural latex is not 'manufacture' as stipulated in Section 80IA of the Income Tax Act, 1961. iii) Whether the learned ITAT gravely erred in not considering the Certificates issued by the Industries Department, Government of Himachal Pradesh, clearly showing t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... med 'manufacturing'. The factum of carrying on manufacturing activity was also not established. The assessee could not produce any electricity bill. There was no evidence of ESI or PF returns nor any evidence of sale of goods. The assessee claimed that books of accounts were burnt in fire and though every effort was made to lodge FIR, the police department did not do so. Reliance was also placed o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... xtaposition with the facts of the present appeal, we have found that the assessee neither produced the records of purchasing raw material nor explained the process of manufacturing and also no proof of sale. For claiming deduction under Section 80IA, the assessee is supposed to explain that the end product, if any, is commercially known differently. However, in the present appeal the assessee even ..... X X X X Extracts X X X X X X X X Extracts X X X X
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