2019 (1) TMI 1018

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....ndent P.C. 1. These appeals arise out of common background and concern same assessee. 2. We may note the facts from Income Tax Appeal No.1044 of 2016. This appeal is filed by the Revenue to challenge the judgment of the Income Tax Appellate Tribunal raising following questions for our consideration : (i) Whether in law and on the facts of the instant case, was the Tribunal in error in ....

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....s also goods produced by outside parties? (iv) Whether in law and on the facts of the instant case, was the Tribunal justified in confirming the orders of the CIT(A) ignoring the fact that all the firm claimed deduction u/s 80HHC without a claim u/s 80IB; thus this claim u/s 80IB for the year was to set off the effect of the sunset clause in the case of Section 80HHC? 3. The assessment year ....

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....ssee pointed out that the assessee had purchased the relevant material only in the Assessment Year 1995-96. The registration of the unit as a Small Scale Industry was also granted in the year 1995-96. The assessee further pointed out that the manufacturing activity had also commenced only from such year. The assessee explained an error in the Audit Report by pointing out that the industrial und....

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.... undertaking for a period of 10 consecutive assessment years, beginning with the initial assessment year. The term "Initial Assessment Year" has been explained in subsection (14) to Section 80IB of the Act inter alia as to mean, in case of an industrial undertaking, the assessment year relevant to the previous year in which the industrial undertaking begins to manufacture or produce articles or th....