For Sec.80-IB “workers” need not be “employees”
The assesee was engaged in the manufacture of goods by using job workers; its total number of permanent employees was less than ten. The department relied on Venus Auto Pvt Ltd vs. CIT 321 ITR 504 (All) and claimed that the non-employment of at least 10 workers was in breach of s. 80IB(2)(iv) and deduction u/s 80IB was not admissible. This was reversed by the Tribunal. On appeal by the department, HELD dismissing the appeal.
The assesee was engaged in the manufacture of goods by using job workers; its total number of permanent employees was less than ten. The department relied on Venus Auto Pvt Ltd vs. CIT 321 ITR 504 (All) and claimed that the non-employment of at least 10 workers was in breach of s. 80IB(2)(iv) and deduction u/s 80IB was not admissible. This was reversed by the Tribunal. On appeal by the department, HELD dismissing the appeal.
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