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In favour of assessee.The Assessee should be allowed deduction u/s.80JJAA of the Act, subject to quantification of the sum to be allowed as deduction by the AO after due opportunity to the Assessee.

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Section 80JJA of the Income Tax Act, 1961 — Deduction — Assessee company engaged in rendering software Development service was to be regarded as an industrial undertaking engaged in manufacture of article or thing so as to be eligible for deduction under section 80JJA— Manhattan Associates India Development Centre P Ltd vs. Deputy Commissioner of income tax [2020] 180 ITD 257 (Bangalore-trib)

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