LIBERTY SHOES LTD. Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) THIS appeal has been preferred by the assessee proposing following substantial questions of law arising out of order of the Tribunal, Delhi Bench 'E', New Delhi, in ITA No. 2809/Del/2001, for the asst. yr. 1996 -97:

(2.) THE assessee computed its income after deducting income of Rs. 37,95,908 under s. 80 -IA of the IT Act, 1961 (in short, 'the Act'). Claim of the assessee was that finished goods were purchased and exported and the said goods were not attributable to manufacturing activities of the assessee. Accordingly, the AO disallowed the claim, which was affirmed by the CIT(A) as well as by the Tribunal. However, claim to the extent the goods were manufactured by the assessee was allowed.

(3.) WE have heard learned counsel for the parties and have perused the relevant finding of the Tribunal on the said questions, which is to the following effect :