The only issue raised by learned counsel for the assessee in the present appeals is that process of dry cleaning is a part of the manufacturing process and thus, the income derived from dry cleaning, job work of the third parties, is also income derived from industrial undertaking having direct and proximate nexus with its manufacturing activities and, therefore, the assessee is entitled to deductions under Section 80-I of the Act. Since the said activity is in the process of export activity as well, therefore, the assessee is entitled to deduction under Section 80-HCC as well. Though the learned Tribunal has referred to the decision of the Tribunal in the assessee's own case for the year 1988-89 and 1989-90 but it is asserted by learned counsel for the assessee that the question of dry cleaning charges, as an income derived from industrial undertaking, was not the issue raised and decided. Similarly, in four other cases, i.e., in ITA No.2251/Chandi/92, assessment year 1991-92, Greatways, No.599/Chandi/94, assessment year 1991-92, Eastman and No.1601/Chandi/93, assessment year 1990-91, Nav Bharat Knitwears and (2007)288 ITR 494, Nahar Exports & Chemicals v. CIT, the orders of the Income Tax Appellate Tribunal also do not deal with dry cleaning process as income derived from industrial undertaking. We have proceeded to examine the issue in the said background.
