Part of manufacturing by outside agency cannot be reason for disallowance of deduction u/s 80IB

DCIT Vs ACE Plastics (ITAT Mumbai) ITAT Mumbai held that disallowance of deduction under section 80IB of the Income Tax Act merely because part of manufacturing activities are being done from outside the unit is unsustainable in law. Facts- The Assessee is into the business of manufacturing of plastic containers, bottles, caps etc., filed return by declaring its income at Rs.39,62,080/- and also claimed deduction u/s. 80IB of the Income Tax Act, 1961 which was accepted by AO by framing the assessment u/s. 143(3). Subsequently, in re -assessment proceedings, AO disallowed Rs.5,46,724/- out of t...