Integrated Cooling System Module Held Distinct Product; 80-IC Deduction Allowed – ITAT Chennai

Alkraft Thermotechnologies Pvt. Ltd Vs DCIT (ITAT Chennai) Assembly Held as Manufacture – Deduction U/s 80-IC Allowed – Expansion ≠ Splitting-Up of Business – Integrated Cooling System Module Is Distinct Product – ITAT Chennai ITAT Chennai allowed deduction u/s 80-IC holding that assembly of components into an integrated engine cooling system module constitutes ‘manufacture/production’ where final product is commercially distinct from inputs. Tribunal rejected AO’s allegation that Uttarakhand unit was merely an assembly or packing unit and held that scientific processing, value...