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The Tax Publishers2020 TaxPub(DT) 0476 (Bom-HC) INCOME TAX ACT, 1961
Section 80IA
Following decision of Supreme Court in case of CIT v. Hindustan Petroleum Corporation Ltd. ((2017) 396 ITR 696 (SC) : 2017 TaxPub(DT) 2054 (SC)), Tribunal rightly held that that bottling of gas into gas cylinders is a production activity for purpose of deduction under sections 80H, 80I and 80IA.
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Deduction under section 80IA - Manufacturing activity or not - Bottling of gas into gas cylinders -
Revenue challenged order of Tribunal holding that bottling of gas into gas cylinders as a production activity for purpose of 80H, 80I and 80IA ignoring the fact that no new production comes into existence in this process. Held: Following decision of Supreme Court in case of CIT v. Hindustan Petroleum Corporation Ltd. ((2017) 396 ITR 696 (SC) : 2017 TaxPub(DT) 2054 (SC)), the substantial questions of law as framed was answered against revenue.
REFERRED :
FAVOUR : In assessee's favour
A.Y. :
INCOME TAX ACT, 1961
Section 14A
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