Income-tax Appeal No. 116 of 2011 -1- **** IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH Income-tax Appeal No. 116 of 2011 Date of decision: 21.11.2011 Commissioner of Income Tax ( Central), Ludhiana ...Appellant Versus M/s Sheena Industries, Ujha Road, Panipat ...Respondent CORAM: HON'BLE MR.JUSTICE HEMANT GUPTA HON'BLE MR.JUSTICE G.S.SANDHAWALIA Present: Mr. Rajesh Katoch, Advocate for the appellant. **** HEMANT GUPTA, J. The revenue is in appeal under Section 260A of the Income Tax Act, 1961 arising out of the order passed by the Income Tax Appellate Tribunal, Delhi Bench 'G', New Delhi dated 26.9.2008 in ITA No.968/Del/2007 for the assessment year 2003-04. The revenue has claimed following substantial question of law:- “Whether, on the facts and in the circumstances of the case, the Hon'ble ITAT was right in law in upholding the order of the CIT(A), directing the A.O. to allow deduction u/s 80HHC to the assessee, who is a supporting manufacturer in the same manner, as in the case of direct exporter, treating the supporting manufacturer at par with the direct exporter and ignoring the provisions of section 80HHC(1A) read with Section 80HHC(3A) read with clause (baa) of explanation of section 80HHC of the I.T.Act, 1961?” Income-tax Appeal No. 116 of 2011 -2- **** Learned counsel for the revenue submits that the said question of law stands decided against the revenue in ITA No.916 of 2008 Commissioner of Income-tax Vs. M/s Sheena Industries, Ujha Road, Panipat decided on 23.11.2009. In view of above, we do not find that any substantial question of law arises in the present case. Consequently, the appeal is dismissed. (HEMANT GUPTA) JUDGE November 21, 2011 (G.S.SANDHAWALIA) Pka JUDGE