1985 (4) TMI 87

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....ction under section 80-I of the Income-tax Act, 1961 ('the Act'). The admitted facts are that the assessee carries on the business of manufacturing polythene bags and in the course of such business, it gets the polythene bags stitched by an outside agency. The Commissioner (Appeals) accepted the contention of the assessee that the assessee was engaged in the manufacture of an article though it get....

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....who were paid wages and who were carrying on the manufacturing process on behalf of the assessee and the matter was remitted to the ITO to ascertain the actual activity of the assessee. In the present case, admittedly, the assessee does not pay any wages to any one who is engaged in the manufacturing process on behalf of the assessee. Therefore, it cannot be said that the assessee employs 10 or mo....