Deduction U/s 80IC can be claimed, despite no chemical change in composition of the raw material during manufacturing process

assessee had set up a unit at Baddi in Himachal Pradesh for packaging of Horlics, Boost for Glaxo Smithkline Consumer Healthcare Ltd. The assessee filed its return of income claiming deduction u/s 80IC of Rs. 6,59,69,287/- @ 100% on the profits of the eligible business alleging that it was engaged in the activity of manufacturing of Horlics & Boost. The AO disallowed the claim of deduction u/s 80IC, inter alia, by observing that in from 3 CD of the audit report the nature of business was shown as “rendering services of job work” (packaging of Hor

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