DCIT, NEW DELHI vs. M/S. ULTIMATE FLEXIBLE LTD, NEW DELHI
ITA 2782/DEL/2009[2006-07]Status: DisposedITAT Delhi20 Mar 2019AY 2006-07
Bench: Shri R. K. Panda & Ms Suchitra Kamble & Ultimate Flexipack Ltd. Vs Dcit 305, 3Rd Floor, Bhanot Corner, Central Circle-18 Pamposh Enclave, Greater Kailash-1 Ara Centre,E-2, Jhandewalan New Delhi Aaacu6565D New Delhi (Appellant) (Respondent) Dcit Vs Ultimate Flexipack Ltd. Central Circle-18 305, 3Rd Floor, Bhanot Corner, Ara Centre, E-2, Jhandewalan Pamposh Enclave, Greater New Delhi Kailash-1 New Delhi Aaacu6565D (Appellant) (Respondent)
Section 115JSection 80Section 80I
…activity of the undertaking would also be excluded. In other words, only income and expenses which have a direct nexus with the manufacturing activity of the undertaking have to be considered and taken into account: i) Zandu Pharmaceutical Works Ltd. vs. CIT 350 ITR 166 (Bom) ii) Bush Boake Allen (India) Ltd. vs. ACIT 273 ITR 152 (Mad) iii) CIT vs. Hindustan Unilever Ltd. 394 ITR 73 (Bom) iv) Liberty India vs. CIT 317 ITR 218 (SC) 7. The Ld. AR submitted that such technical know-how which has been acquired by the assessee from Mr. Ashok Chaturvedi has been shared by the assessee not only for the manufacture of…