2014 (9) TMI 724

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....dent-assessee was engaged in manufacture of goods and things to claim deduction under Section 80-IC of the Income Tax Act, 1961 ("Act", for short). The claim was disallowed by the Assessing Officer, but stands allowed by the Commissioner of Income Tax (Appeals), a finding affirmed by the Income Tax Appellate Tribunal ("Tribunal", for short). 2. The respondent-assessee was engaged in the business of manufacture of health care and surgical items and in the returns filed for Assessment Years 2006-07, 2008-09 and 2009-10 had declared taxable income of Rs. 26,25,230/-, Rs. 94,90,363/- and Rs. 32,18,350/- respectively. The deduction claimed under Section 80-IC of the Act was to the tune of Rs. 42,90,162/-, Rs. 35,69,594/- and Rs. 2,46,13,965/- r....

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....romoting it aggressively all dyer the North Indian Market. Details regarding our marketing activities and already existing approvals have been given in the latter part of this report. Steri-Air is a versatile system, which can be used in almost all areas of a hospital on a continuous 24x7 basis. Manufacturing of Steri-Air is an assembly process, where we procure various parts/components of the system from different vendors and assemble the same at our facility in Roorkee. All the electronic and electrical components are received in the form of cards, with suitable connectors and all the required cards are connected using connectors". 3. The term "manufacture" has been defined in Section 2(29BA) of the Act, which is as under:- "2(29BA) "....