- (1.) Affidavit of service filed in Court today be kept with the records.
(2.) The assessee claimed deduction under Sections 80IB and 10B of the Income Tax Act, 1961 in respect of its units at Silvasa and Puducherry respectively. The assessee claims to manufacture diesel generating sets from these units. Claims of the assessee for deduction under both these provisions were disallowed by the Assessing Officer mainly on the ground that the assessee was not engaged in any manufacturing or production activities. On appeal by the assessee, the Commissioner of Income Tax (Appeals) found the assessee to be eligible for deduction under both these heads. Further appeal of the Revenue before the Tribunal, which was registered as ITA No. 806/Kol/2013 along with the assessee's cross-objection (No.48/Kol/2013) were also decided in favour of the assessee.
(3.) There are various conditions stipulated in the aforesaid provisions to entitle manufacturing units for deduction. But so far as this appeal is concerned, the ground on which we are to address is as to whether the Assessee's activities constituted manufacturing activities/production or not. That is one of the essential conditions for deduction under both the aforesaid provisions.;