Section 80IC benefit ineligible to unit outsourcing most of production process

CIT Vs Usha Infrasystems (Himachal Pradesh High Court) Himachal Pradesh High Court held that benefit u/s 80IC not available when only small part of entire process is carried out at unit and other process is outsourced. Facts- The respondent had begun production of Foundation Anchor Rods for Windmills w.e.f. 29.06.2004 in Industrial Area Parwanoo. The assessee, for the first time, claimed 100% deduction on the income u/s. 80IC(2)(ii) of the Income Tax Act, 1961. AO denied the deduction. AO and CIT(A) concurrently held that since the substantial process involved in production of Anchors was bein...