Transformation of articles to bring new articles into existence amounts to manufacturing

DCIT Vs Himalayan Auto Era (India) Pvt. Ltd. (ITAT Delhi)

The issue in the present ground is with respect to the denial of claim of deduction u/s 80IC of the Act. The claim of deduction u/s 80IC of the Act was denied by the AO for the reason that according to him assessee was not engaged in the business of manufacturing of any new product but was engaged in job work. We find that CIT(A) by following the order of his predecessor for A.Y. 20 12-13 held the assessee to be engaged in the business of manufacturing and held that assessee to be eligible for de

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