1996 (11) TMI 24

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....978-79 : Whether, on the facts and in the circumstances of the case, the Tribunal was right in law in holding that hiring of certain machineries from sister concern would not amount to transfer as provided under s. 80J(4)(ii) of the IT Act, 1961? Asst. yr. 1979-80 : Whether, on the facts and in the circumstances of the case, the Tribunal was right in law in holding that hiring of certain mac....

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.... raised on account of the contention by the Departmental Representative before the Tribunal that in respect of the exploitation of forest and sizing of timber no activity was undertaken during the accounting period relevant to the assessment year under appeal and, therefore, the benefit of that section was not available to the assessee. It was rejected by the Tribunal by the following reasoning in....

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.... that the income is derived from such activity. It is immaterial whether any manufacturing was done during the accounting period relevant to the assessment year under appeal so long as the goods sold were from such activity even in earlier years. The goods which were sold during the accounting period relevant to the assessment year under appeal were manufactured by the assessee in the industrial u....