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TMI Blog1984 (9) TMI 84X X X X Extracts X X X X X X X X Extracts X X X X ..... s follows: The assessee, a private limited company, had for the first two years of its existence purchased furniture goods and wooden structures form the market, made certain alterations to suit the requirements of the customers, pained them and sold them and sold them. In the meanwhile, the assessee acquired a piece of land in the Baroda Industrial Area and set up a building a house a factory. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s not entitled to the deduction. 3. CIT (A), however, felt that the assessee was entitled to the deduction. According to him, in the earlier two years, the assessee had only manufactured proto types in wooden. Merely because the proto types could be sold in the earlier years, it would not mean that the business had already started. In the present case, district new unit had been set up. This had ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the first two years the assessee was merely doing trading business. It is only in this year that the manufacturing operations had started. She further submitted that in the earlier years no claim for deduction under s. 80J was made. Only during the previous year under consideration that the assessee could get the machines installed, electricity connection given and recognition granted as a small ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l expenditure of Rs. 72,905. Plant & machinery of Rs. 3,37,964 wee installed during the accounting year concerned. Electricity connection was received during this year. The assessee had started production only during this year. We are quite satisfied that this is not a case of splitting up of an existing business. It is also not a case of expansion of an existing business by mere addition of one o ..... X X X X Extracts X X X X X X X X Extracts X X X X
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