TaxTMI 
TaxTMI 
2026 (1) TMI 456
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....venue has filed an application citing reasons causing delay in filing of appeal. After perusal of the same, we are satisfied that delay in filing of appeal is not intentional, the delay has been caused for the reasons stated in petition which appears to be bonafide. Thus, delay of 50 days in filing of appeal is condoned and appeal is admitted for decision on merits. 3. The Revenue in appeal has raised following grounds: "1. Whether, on the facts and circumstances of the case and in law the Ld. CIT(A) has erred in deleting the disallowance of Rs. 4,81,03,713/- without appreciating that the segregation charges were established to be technical services as per explanation 2 of Section 9(1)(vii) of the Income Tax Act and the assessee....
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....sel for the assessee referring to his written submissions filed before the CIT(A) submitted that the nature of rework and The work involves inspection of the product, segregation involve different steps which are to be done manually or using automatic equipment depending on the type and volume of the item to be sorted. The manual sorting involves human operators who individually inspect each item and sort them based on the predetermined criteria. Whereas, automatic sorting is with mechanical equipments such as conveyer systems, optical sensors, based on predetermined criteria. Automatic sorting is often used in high volume production environment. The technical specifications of any part cannot be modified or altered during the process of re....
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....organize, categorize, or separate items based on their properties or characteristics. Sorting can be done manually using tools such as trays, bins, or racks to physically separate items based on specific criteria. Automated sorting can involve the use of conveyor systems, sensors, or sorting machines, filters that utilize mechanical, optical, or other process to sort items based on predetermined criteria i.e. predefined specifications of the parts. ii. Removal of metal chips: This refers to the process of eliminating metal chips or shavings that are generated during machining or other metalworking operations. Metal chips are small pieces of metal that are typically created when cutting, grinding, milling, or drilling metal material....
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.... during the initial threading process. b. These processes can be done manually or using automated equipment, depending on the type and volume of items to be sorted. Manual sorting involves human operators who visually inspect each item and sort them based on the predetermined criteria. For example, in a warehouse or distribution center, workers may sort items based on their destination or final location for shipping. Automated sorting, on the other hand, involves the use of mechanical equipment, such as conveyor systems, optical sensors to sort items based on predetermined criteria. Automated sorting is often used in high-volume production environments, such as manufacturing facilities, where speed and accuracy are critical for eff....