2015 (2) TMI 668

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....come up in appeal. Mr. Saraf, learned advocate appearing for the Revenue, submitted that the view taken by the learned Tribunal is patently contrary to the statute. In order to claim the benefit under section 10B of the Income-tax Act, one of the requirements is to be found in clause (iv) of Explanation 2 under sub- section (8) of section 10B of the Income-tax Act which reads as follows:              " 'hundred per cent. export-oriented undertaking' means an under taking which has been approved as a hundred per cent. export oriented undertaking by the Board appointed in this behalf by the Cen tral Government in exercise of the powers conferred by section 14 of the Industr....

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....vals." The assessee has relied upon, as would appear from the assessment order, the following :             "A letter was written to the General Manager, District Industries Centre, Directorate of Cottage and Small Scale Industries requesting them to state whether they have the authority to issue certificate for the purpose of deduction under section10B of the Income-tax Act, 1961. In response the General Manager, District Industries Centre, vide his letter dated July 4, 2005, categorically stated that the General Manager is merely the registering authority for allowing permanent/ final small scale industries registration certificate to the SSI units approached for this purpose and is....