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    <title>2017 (9) TMI 957 - ITAT RAJKOT</title>
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    <description>Eligibility for deduction under section 10B turned on the actual year in which the unit commenced manufacture or production. Contemporaneous records showed that machinery and electrical fittings were not available in the earlier year, the balance sheet reflected only a shed, there was no business activity or profit and loss in that year, and registration and utility records supported commencement only in the later year. The accountant&#039;s earlier date entry was treated as inadvertent and inconsistent with the surrounding evidence. On that factual basis, the beneficial export-oriented deduction was allowed and the objection based solely on the certificate was rejected.</description>
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      <link>https://www.taxtmi.com/caselaws?id=348200</link>
      <description>Eligibility for deduction under section 10B turned on the actual year in which the unit commenced manufacture or production. Contemporaneous records showed that machinery and electrical fittings were not available in the earlier year, the balance sheet reflected only a shed, there was no business activity or profit and loss in that year, and registration and utility records supported commencement only in the later year. The accountant&#039;s earlier date entry was treated as inadvertent and inconsistent with the surrounding evidence. On that factual basis, the beneficial export-oriented deduction was allowed and the objection based solely on the certificate was rejected.</description>
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