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    <title>2014 (1) TMI 911 - ITAT AHMEDABAD</title>
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    <description>Deduction under section 80IB depends on factual proof that manufacturing or production began within the prescribed time and that the industrial undertaking satisfied the statutory conditions. The date of issue of a factory licence was not treated as conclusive by itself, because timely application and the actual commencement of manufacturing required verification. Scrap sale income could be included in eligible profits only if the scrap was generated in the course of manufacturing and derived from the industrial undertaking; that factual basis was also not established. Both issues were remitted for fresh examination, with the Revenue succeeding only for statistical purposes.</description>
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      <link>https://www.taxtmi.com/caselaws?id=242695</link>
      <description>Deduction under section 80IB depends on factual proof that manufacturing or production began within the prescribed time and that the industrial undertaking satisfied the statutory conditions. The date of issue of a factory licence was not treated as conclusive by itself, because timely application and the actual commencement of manufacturing required verification. Scrap sale income could be included in eligible profits only if the scrap was generated in the course of manufacturing and derived from the industrial undertaking; that factual basis was also not established. Both issues were remitted for fresh examination, with the Revenue succeeding only for statistical purposes.</description>
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