AO rejected claim u/s 80IB on ground that manufacturing activity undertaken by that other entity for and on behalf of Assessee was not under its direct supervision and control. Order of the AO was affirmed by the CIT(A) and Appellate Tribunal. On appeal dismissing the appeal of the assessee the Court held that the ssessee could not produce particulars like attendance register, qualifications of employees in spite of being asked to do so by AO. In fact, it appeared that even packaging material was supplied to contract manufacturer by Assessee-Company for finished products. The Assessee did not retain control over manufacturing of electronic computers at factory premises of that other entity. Accordingly not eligible for  deduction.  ( AY. 2004 -05)