2010 (4) TMI 16

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....tate of Punjab. It claimed deduction under Section 80-I of the Income Tax Act, 1961 for the Assessment Year 1990-91, which, according to the assessee, is the initial assessment year. The deduction was initially allowed by successive Assessing Officers for the initial Assessment Year 1990-91 and for six successive Assessment Years 1991-92 to 1996-97. For the Assessment Year 1997-98, the Assessing O....

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....or the reason that in the Annual Report of the assessee for Financial year1988-89, relevant to the Assessment Year 1989-90, assessee had indicated sales of 346 engines manufactured before 31st March, 1989. Taking into account the said particulars of sales, the notice stated that the manufacturing/production of engines had allegedly started in the period, relevant to the Assessment Year 1989-90, an....

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....al, we are informed that against the order of the Assessing Officer reopening the assessment, the assessee herein had preferred an Appeal to CIT(A). By his order dated 8th January, 2007 in Appeal No.65/P/03-04, the CIT(A) allowed deduction under Section 80-I for the Assessment Year 1997-98 on the ground that assembling of engine did not amount to manufacture for the purposes of claiming deduction ....