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    <title>2015 (3) TMI 766 - DELHI HIGH COURT</title>
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    <description>Assembly of audio and video cassettes from finished components was treated as manufacture because it produced a distinct, marketable commercial commodity, supporting deductions under Sections 80HH, 80I and 80IA. Concurrent factual findings that the Namoli and Malanpur units were operational, based on records such as employee, electricity, inspection and excise materials, justified the deductions and depreciation. The record did not establish suppression of sale price in video cassette transactions. The Noida unit&#039;s loss was reworked on actual allowable expenditure and the partial allowance was sustained. Foreign exchange fluctuation loss on raw material purchases was treated as revenue expenditure, and the Revenue&#039;s appeals failed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=257832</link>
      <description>Assembly of audio and video cassettes from finished components was treated as manufacture because it produced a distinct, marketable commercial commodity, supporting deductions under Sections 80HH, 80I and 80IA. Concurrent factual findings that the Namoli and Malanpur units were operational, based on records such as employee, electricity, inspection and excise materials, justified the deductions and depreciation. The record did not establish suppression of sale price in video cassette transactions. The Noida unit&#039;s loss was reworked on actual allowable expenditure and the partial allowance was sustained. Foreign exchange fluctuation loss on raw material purchases was treated as revenue expenditure, and the Revenue&#039;s appeals failed.</description>
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