2014 (12) TMI 1423

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....J) 1. The appeal by the assessee is directed against the order dated 03/10/2011 passed by the ld. CIT(A) for the assessment year 2008-09, on the following grounds. 1. The learned Commissioner of Income Tax (Appeal) has erred in fact and in law in holding that income derived from job work activity etc. by eligible unit u/s. 80IB are not derived from eligible business of eligible industrial under....

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....other hand, the ld. DR, Shri Niel Philip, contended that there is no manufacturing as such, therefore, the claimed deduction u/s. 80IB of the Act was rightly denied to the assessee. 2.1. We have considered the rival submissions and perused the material available on record. The facts, in brief, are that the assessee is engaged in the business of manufacturing of lubricating oil and antistatic conn....

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....uary, 2013, CIT vs. Impel forge and allied Industries Ltd. (2008-TIOL-760-HC-P & H-IT), CIT vs. Sadhu Forging Ltd. (2011-TIOL-361-HC-Del-IT), Liberty India vs. CIT 317 ITR 218, we are of the view, that the assessee is entitled for deduction u/s. 80IB of the Act. Even otherwise, a provision in the taxing statute granting incentives for promoting growth and development should be construed liberally.....

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....laid down in CIT vs. Vinbros & Company 210 Taxman 252 (SC), CIT vs. Zainab Trading Pvt. Ltd. 333 ITR 144 (Mad.), CIT vs. Esquire Translam Industries 344 ITR 308 (Mad.), Titanor Components Ltd. vs. CIT 197 Taxman 441 (Del.), CIT vs. Ambuja Ginning Pressing & Oil Company Pvt. Ltd. 203 Taxman 34 (Mag)/15 Taxman.com 273 (Guj.) and Midas Polymer Compounds Pvt. Ltd. vs. ACIT (2011) 197 Taxman 481(Ker.)(....