Separate or disassemble parts of plant, even if assembled abroad, considering size of the plant, quality for exemption u/s 10B

Brief Facts of the case 1. There are two appeal that need to be answered (i) For AY 2007-08 assessee had had claimed deduction/exemption under Section 10B of the Income Tax Act, 1961 (Act, for short) on profit of Rs.69,69,429/- from the Noida Unit. The Assessing Officer did not allow deduction under Section 10B on the ground that the assessee had not manufactured any goods in the Noida Unit. He referred to reply received from R.N. Metals, Jaipur, M/s Sustul Engg. Corp. Mumbai, M/s Chanderpur Works Yamuna Nagar (Haryana) to the effect that they had manufactured and exported various goods on beh...