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2024 Supreme(Online)(ITAT) 988

INCOME TAX APPELLATE TRIBUNAL (BANGALORE BENCH)
Waseem Ahmed, ACJ, Keshav Dubey, J
INFOSYS LIMITED BANGALORE – Appellant
Versus
DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1) BANGALORE – Respondent


Advocates:
For the Appellants/Petitioners: Shri P.C Kincha, C.A
For the Respondents: Shri A Sreenivasa Rao, CIT (DR)

Table of Content
1. grounds for appeal by the assessee. (Para 1 , 2)
2. court dismisses ground no. 1. (Para 3 , 4)
3. ao's stance on deduction under section 32ac. (Para 5 , 6 , 7)
4. assessee argues for eligibility under section 32ac. (Para 8 , 9)
5. court's assessment of prior cases. (Para 10 , 11)
6. definition of manufacture as per it act. (Para 12)
7. exclusion of income types from 10aa computation. (Para 13 , 14)
8. final conclusion on appeal regarding section 10aa. (Para 15 , 16 , 19 , 20)

ORDER

PER WASEEM AHMED, ACCOUNTANT MEMBER:

This is an appeal filed by the assessee against the order passed by the NFAC, Delhi dated 27/03/2024 in DIN No. ITBA/NFAC/S/250/2023-24/1063442931(1) for the assessment year 2016-17.

2. The assessee has raised the following grounds of appeal:

“1. General around:

1.1. The learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (hereinafter referred to as CIT(A) for short) has erred in passing the order under section 250 in the manner passed by him. The order so passed to the extent prejudicial to the appellant is bad in law and liable to be quashed.

2. Disallowance of deduction under section 32AC:-

2.1. The learned CIT(A) has erred in not allo

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