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    <title>2024 (2) TMI 39 - ITAT DELHI</title>
    <link>https://www.taxtmi.com/caselaws?id=448888</link>
    <description>ITAT Delhi ruled in favor of the assessee regarding Section 80IC deduction eligibility. The tribunal held that the assessee&#039;s activities of processing raw materials received from HUL and feeding processed materials to HUL&#039;s mother plant constituted manufacturing, not merely contract services. The tribunal found that regulatory authority approvals supported the manufacturing nature of operations. The AO&#039;s reliance on HUL&#039;s confirmation stating activities were only contract services was deemed improper as it wasn&#039;t confronted with the assessee during assessment proceedings. The tribunal set aside both the assessment order and CIT(A)&#039;s order, directing the AO to allow Section 80IC benefits. The assessee&#039;s appeals were allowed.</description>
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    <pubDate>Tue, 30 Jan 2024 00:00:00 +0530</pubDate>
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      <title>2024 (2) TMI 39 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=448888</link>
      <description>ITAT Delhi ruled in favor of the assessee regarding Section 80IC deduction eligibility. The tribunal held that the assessee&#039;s activities of processing raw materials received from HUL and feeding processed materials to HUL&#039;s mother plant constituted manufacturing, not merely contract services. The tribunal found that regulatory authority approvals supported the manufacturing nature of operations. The AO&#039;s reliance on HUL&#039;s confirmation stating activities were only contract services was deemed improper as it wasn&#039;t confronted with the assessee during assessment proceedings. The tribunal set aside both the assessment order and CIT(A)&#039;s order, directing the AO to allow Section 80IC benefits. The assessee&#039;s appeals were allowed.</description>
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      <pubDate>Tue, 30 Jan 2024 00:00:00 +0530</pubDate>
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