2005 (2) TMI 830

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....account of processing charges and as such they were not involved in the activity of manufacturing. Thus, the benefit of Section 80-IA would not be available to the assessed. This question is primarily- a question of fact and has been answered by the Tribunal as follows : "The assessed was deriving processing charges as a result of products manufactured on job work basis for outsiders. The on....

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....ntial prerequisite under Section 80-IA is that the eligible industrial undertaking should be carrying out the manufacture or production of articles or things, an issue which presently is not in dispute before us. It is also noteworthy that the assessing authority in the earlier assessment year i.e., 1995-96 has allowed the claim of the assessed for deduction under Section 80-IA. Therefore, having ....