1992 (11) TMI 149

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....irm is in appeal on the following grounds of objections: (i) The CIT(A) erred in confirming the application of net profit rate of 12.5% of the contract receipts. (ii) The CIT(A) erred in confirming the disallowance of deduction under s. 80HH in the asst. yr. 1985-86 and under s. 80-I of the IT Act, 1961, in the asst. yr. 1986-87. 2. Learned Representatives of the parties are heard. The as....

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....tion. 3. So far as allowability of deductions under s. 80HH in the asst. yr. 1985-86 and ss. 80HH and 80-I in the asst. yr. 1986-87 are concerned, in our judgment, the assessee is entitled to the same. The assessee was engaged in the business of construction of overhead water tanks, which require construction of piles. The construction of piles itself is a process of manufacture. In this connec....