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“deduction under section 80IA”

DeductionsSection 80IASection 80IA554 judgments

The decision most relied on for deduction under section 80IA is Liberty India v. CIT (317 ITR 218), cited in 571 judgments on BharatTax.

Leading authorities on deduction under section 80IA

Liberty India v. CIT
317 ITR 218 · 2009 · Supreme Court
571
citing judgments

The Supreme Court clarified that for profits and gains to be eligible for deductions under sections like 10B, 80IA, or 80IB, the income must be "derived from" or have a direct nexus to the eligible business activity. Income from incidental sources like the sale of scrips/licenses or interest on employee loans is generally not considered as derived from the eligible business for such deductions.

Pandian Chemicals Ltd. v. CIT
262 ITR 278 · 2003 · Supreme Court
353
citing judgments

Income eligible for deduction under Section 80IA or 80IC must have a direct nexus with the eligible business activity of the industrial undertaking. Income merely incidental to the business, even if part of the assessee's overall business, is not considered "derived from" the eligible undertaking.

M.M.Aqua Technologies Limited v. CIT
436 ITR 582 · 2021 · Supreme Court
308
citing judgments

Amendments to tax law that impose new obligations or change existing legal positions apply prospectively, even if stated to be "for the removal of doubts." The judgment also clarifies that deductions under Section 43B are allowed only on actual payment, overriding the mercantile system of accounting.

Bajaj Tempo Ltd. v. CIT
196 ITR 188 · 1992 · Supreme Court
289
citing judgments

Provisions in taxing statutes that grant incentives, concessions, or exemptions for promoting economic growth and industrialization must be interpreted liberally and purposively. Any restrictions placed on such provisions should also be construed reasonably to advance their objective, not frustrate it.

CIT v. ABG Heavy Industries Ltd.
322 ITR 323 · 2010 · High Court
229
citing judgments

The Assessing Officer cannot deny a Section 80IA deduction by merely asserting that the assessee is not a "developer" without considering the relevant agreements and facts. Entitlement to Section 80IA deduction requires a thorough examination of the assessee's role as a developer.

CIT v. Paul Brothers
216 ITR 548 · 1995 · High Court
164
citing judgments

Once a claim for deduction under section 80-IA or 80-IB is allowed in the initial assessment year and is not subsequently withdrawn, the revenue is estopped from denying the deduction for subsequent years on the same grounds.

CIT v. Contimeters Electricals (P.) Ltd.
317 ITR 249 · 2009 · High Court
140
citing judgments

The requirement to file an audit report along with the return of income under section 80-IA(7) and similar provisions is directory, not mandatory. Such a report suffices if filed at any time before the assessment is framed.

CIT v. Karnal Co-operative Sugar Mills Ltd.
243 ITR 2 · 2000 · Supreme Court
125
citing judgments

Income earned from deposits or investments directly and inextricably linked to the acquisition of assets or the setting up of a business project during its construction period is incidental to the asset acquisition, reducing the project cost, or constitutes business receipts eligible for relevant deductions, rather than 'income from other sources'.

Judgments citing deduction under section 80IA

Candor Kolkata One Hi- Tech Structures Pvt. Ltd., Maharashtra vs. DCIT, Circle- 18(1), New Delhi

Appeals stand allowed

ITA 6315/DEL/2017[2010-11]Status: DisposedITAT Delhi14 Jun 2023AY 2010-11

Bench: Sh. Anil Chaturvedi & Sh.Anubhav Sharma

Section 115JSection 14ASection 14A(2)Section 80

IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH ‘B’ : NEW DELHI) BEFORE SH. ANIL CHATURVEDI, ACCOUNTANT MEMBER AND SH.ANUBHAV SHARMA

Ga Infra Private Limited, Jaipur vs. PCIT, Jaipur-2

In the result, appeal of the assessee is allowed

ITA 219/JPR/2023[2018-19]Status: DisposedITAT Jaipur14 Jun 2023AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Manish Agarwal (C.A.)For Respondent: Shri Shailendra Sharma (CIT) a
Section 142(1)Section 143(2)Section 143(3)Section 263Section 80I

revenue as the order is passed by the FAO (assessing officer) in a routine and perfunctory manner without examining the issue of deduction under section 80IA. Thus, ld. PCIT has set aside the assessment order on the issue of deduction u/s 80IA. Aggrieved of the order so passed ... available on record, the Assessing Officer failed to consider/apply his mind to the information available on record with regard to the issue of deduction under section 80IA . This in turn has resulted in passing of an erroneous 10 GA Infra Private Limited order by the Assessing Officer in the case

Hubergroup India Private Limited, Vapi vs. Pr. Commissioner of Income Tax, Valsad

In the result, appeal of the assessee is dismissed

ITA 133/SRT/2022[2018-19]Status: DisposedITAT Surat06 Jun 2023AY 2018-19

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.133/Srt/2022 (Ay 2018-19) (Hearing In Virtual Court) Hubergroup India Pvt. Ltd. Principal Commissioner Of Plot No.808/E, Phase-Ii, Income Tax, Valsad, Room Vs Gidc, Vapi-396195 No.301, 3Rd Floor, Income Tax Pan No. Aaach 7063 F Office, Palak Arcade, Pali Hill, Santi Nagar, Tithal Road, Valsad-396001 ""थ" /Respondent अपीलाथ"/Appellant

Section 143(1)Section 143(3)Section 144BSection 254(1)Section 263Section 80ISection 92C

manufacturing units. The Assessing Officer was of the view that in earlier years i.e. in AY 2015-16, 206-17, & 2017-18, the deduction under section 80IA was disallowed on the basis of report of TPO on the view that boiler division cannot exist independently without manufacturing division, the Boiler ... asset acquired for so called unit of Boiler divisions are primarily meant for production of ink. The assessing officer proposed disallowance of deduction under section 80IA in the draft assessment order in his show cause notice. In response to show cause notice on the proposed additions in the draft

DCIT 3(1), Bhopal vs. M/S Nhdc Ltd, Bhopal

In the result, both the appeals filed by the Revenue are dismissed

ITA 315/IND/2020[2014-15]Status: DisposedITAT Indore16 May 2023AY 2014-15

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri B.M. Biyani (Accountant Member)

Section 143(3)Section 2(30)Section 263Section 62Section 79Section 80I

NHDC Ltd. the Act. Further it is not the case of the AO that these expenditures are related to the income on which deduction under section 80IA has been claimed. The only issue with the AO is that the interest income earned by the assessee

DCIT 3 (1), Bhopal vs. M/S Nhdc Ltd, Bhopal

In the result, both the appeals filed by the Revenue are dismissed

ITA 314/IND/2020[2013-14]Status: DisposedITAT Indore16 May 2023AY 2013-14

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri B.M. Biyani (Accountant Member)

Section 143(3)Section 2(30)Section 263Section 62Section 79Section 80I

NHDC Ltd. the Act. Further it is not the case of the AO that these expenditures are related to the income on which deduction under section 80IA has been claimed. The only issue with the AO is that the interest income earned by the assessee

Viramgam Mahesana Projects Pvt. Ltd., New Delhi vs. ACIT, Central Circle- 14, New Delhi

The appeal is allowed

ITA 220/DEL/2018[2014-15]Status: DisposedITAT Delhi15 May 2023AY 2014-15

Bench: Sh. Shamim Yahya & Sh. Anubhav Sharmaita No. 220/Del/2018, A.Y. 2014-15 M/S. Viramgam Mahesana Vs. Acit Project Ltd. Cc-14, E-9, 3Rd Floor, New Delhi South Extension Part-Ii, New Delhi 110049 Pan : Aabcv7027L (Appellant) (Respondent)

Section 143(3)Section 80I

what was derived in the form of return from permitted securities was very much part of the business income from eligible business allowed deduction under Section 80IA of the Act. 10. Thus, the investments in permitted investments under the Escrow Account opened in pursuance of Concession agreement with Western Railways

Dy CIT CC 1(4), Mumbai vs. M/S Ultratech Cement Ltd, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 931/MUM/2020[2015-16]Status: DisposedITAT Mumbai12 May 2023AY 2015-16

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Ultratech Cement Limited V. Dcit, Central Circle-1(4) Ahura Centre, ‘B’ Wing 2Nd Floor Room No. 902, 9Th Floor Mahakali Caves Road Pratishtha Bhavan, Old Cgo Annexe Maharishi Karve Road Andheri (E), Mumbai- 400093 Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) Dcit, Central Circle-1(4) V. M/S. Ultratech Cement Limited Room No. 902, 9Th Floor Ahura Centre, ‘B’ Wing 2Nd Floor Mahakali Caves Road Pratishtha Bhavan, Old Cgo Annexe Maharishi Karve Road Andheri (E), Mumbai- 400093 Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent)

Section 115Section 32Section 32ASection 80I

noted that amendment provision brought in by the Finance Act, 2007 is free from any ambiguity and pursuant to such amendment, deduction under section 80IA becomes impermissible for the amalgamated company in respect of the undertakings inherited under the scheme of amalgamation. 27. The Ld AR of the assessee ... section (12A) merely negates the effect of such disabling provision and it does not restrict the eligibility of an undertaking to claim deduction under section 80IA of the IT Act which is granted under sub-section (1) of section 80IA of the IT Act. 36. The Ld AR also submitted

Ultratech Cement Ltd, Mumbai vs. DCIT CC 1(4), Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 465/MUM/2020[2015-16]Status: DisposedITAT Mumbai12 May 2023AY 2015-16

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Ultratech Cement Limited V. Dcit, Central Circle-1(4) Ahura Centre, ‘B’ Wing 2Nd Floor Room No. 902, 9Th Floor Mahakali Caves Road Pratishtha Bhavan, Old Cgo Annexe Maharishi Karve Road Andheri (E), Mumbai- 400093 Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) Dcit, Central Circle-1(4) V. M/S. Ultratech Cement Limited Room No. 902, 9Th Floor Ahura Centre, ‘B’ Wing 2Nd Floor Mahakali Caves Road Pratishtha Bhavan, Old Cgo Annexe Maharishi Karve Road Andheri (E), Mumbai- 400093 Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent)

Section 115Section 32Section 32ASection 80I

noted that amendment provision brought in by the Finance Act, 2007 is free from any ambiguity and pursuant to such amendment, deduction under section 80IA becomes impermissible for the amalgamated company in respect of the undertakings inherited under the scheme of amalgamation. 27. The Ld AR of the assessee ... section (12A) merely negates the effect of such disabling provision and it does not restrict the eligibility of an undertaking to claim deduction under section 80IA of the IT Act which is granted under sub-section (1) of section 80IA of the IT Act. 36. The Ld AR also submitted

Bsl Ltd., Rajasthan vs. DCIT, Central Circle- 31, New Delhi

In the result, appeal of the assessee is allowed

ITA 6612/DEL/2018[2011-12]Status: DisposedITAT Delhi12 May 2023AY 2011-12

Bench: Sh. Anil Chaturvedi & Sh. Yogesh Kumar Usbsl Ltd., Vs. Dcit 26, Industrial Area, Central Circle-31, Post Box No. 17, New Delhi. Gandhi Nagar, Bhilwara, Rajasthan-311 001 Pan No. Aabcb0639G (Appellant) (Respondent) Assessee By Shri Satyajeet Goel, Adv. Revenue By Shri Kanv Bali, Sr. Dr Date Of Hearing: 03.05.2023 Date Of Pronouncement: 12.05.2023 Order Per Anil Chaturvedi, Am : This Appeal Filed By The Assessee Is Directed Against The Order Dated 29.08.2018 Of The Commissioner Of Income Tax (Appeals)-4, Kolkata Relating To Assessment Year 2011-12. 2. Assessee Is The Company Stated To Be Engaged In The Business Of Manufacturing & Trading Of Synthetic/Wollen/Worsted Yarn Fabrics & Synthetics Fabrics, Manufacturing & Trading Of Ready-Made Garments, Generation Of Power, Processing Of Synthetics Etc. Assessee Electronically Filed Its Return Of Income Bsl Ltd. Vs. Dcit 2

Section 115JSection 143(3)Section 801Section 80I

before the Tribunal was whether the profit earned during the Assessment BSL Ltd. Vs. DCIT 8 Year 2009-10 would be entitled for deduction under Section 80IA(5) of the Act without deducting the losses, which were absorbed in the earlier years. 8. The said issue is now no longer

Jsw Steels Ltd, Mumbai vs. DCIT CC 8(3), Mumbai

In the result, the appeal by the assessee is allowed for statistical purposes

ITA 2116/MUM/2017[2012-13]Status: DisposedITAT Mumbai04 May 2023AY 2012-13

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Shri Rishabh Shah a/wFor Respondent: Dr. Yogesh Kumar
Section 115JSection 142(1)Section 143(2)Section 143(3)Section 144C(1)Section 144C(13)Section 144C(5)Section 14ASection 801ASection 80I

India. For the year under consideration, the assessee filed its return of income on 29/11/2012 declaring a total income of Rs.Nil after claiming deduction under section 80IA of the Act amounting to Rs.508,78,30,027. The return filed by the assessee was selected for scrutiny and statutory notices under ... Having considered the submissions of both sides and perused the material available on record, we find that the assessee has been claiming deduction under section 80IA on profits from “Rail System” from the assessment year 2008-09 onwards, year after year, as under:- Sl. Amount of deduction claimed

Godawari Power and Ispat Ltd., Raipur vs. Deputy Commissioner of Income Tax, National Informatics Center, Delhi

In the result, appeal of the assessee is allowed

ITA 42/RPR/2022[2017-18]Status: DisposedITAT Raipur24 Apr 2023AY 2017-18

Bench: SHRI RAVISH SOOD (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

For Respondent: Smt. Ila M. Parmar, CIT-DR
Section 142(1)Section 143(2)Section 270ASection 80Section 80ISection 92BSection 92C

erred in determining the price for transfer of power between eligible units and non-eligible units as assessee has not claimed any deduction under section 80IA of the Act and thus, provisions of specified domestic transfer pricing as laid down in section 92BA of the Act do not apply ... initiate penalty proceedings against the Assessee under section 270A of the Act, without appreciating the fact that the Assessee has not claimed any deduction under section 80IA of the Act and hence, there is no adjustment to the returned income declared by the Assessee. 2. Brief facts of the case

Bharuch Enviro Infrastructure Ltd., Ankleshwar vs. Addl.CIT, Bharuch Circle, Bharuch

In the result, this appeal of the assessee is partly allowed

ITA 504/AHD/2015[2011-12]Status: DisposedITAT Surat24 Apr 2023AY 2011-12

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 143(3)Section 147Section 148Section 234BSection 234B(3)Section 254(1)Section 80Section 80I

facts and in the circumstances of the case and in law, the CIT(A) erred in not appreciating that once deduction under section 80IA was granted in the initial assessment year, it ought to be allowed in the subsequent years for the remaining period. Bharuch Enviro Infrastructure Ltd. Vs DCIT ... case and in law, the CIT(A) erred in holding that Incinerator Project 2 is not a separate undertaking and not eligible for deduction under section 80IA of the Act separately despite the fact that the said undertaking had started its operation from AY 2012-13 and the said issue

Bharuch Enviro Infrastructure Ltd., Ankleshwar vs. ACIT, Bharuch Circle, Bharuch

In the result, this appeal of the assessee is partly allowed

ITA 503/AHD/2015[2010-11]Status: DisposedITAT Surat24 Apr 2023AY 2010-11

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 143(3)Section 147Section 148Section 234BSection 234B(3)Section 254(1)Section 80Section 80I

facts and in the circumstances of the case and in law, the CIT(A) erred in not appreciating that once deduction under section 80IA was granted in the initial assessment year, it ought to be allowed in the subsequent years for the remaining period. Bharuch Enviro Infrastructure Ltd. Vs DCIT ... case and in law, the CIT(A) erred in holding that Incinerator Project 2 is not a separate undertaking and not eligible for deduction under section 80IA of the Act separately despite the fact that the said undertaking had started its operation from AY 2012-13 and the said issue

Bharuch Enviro Infrastructure Ltd., Ankleshwar vs. Dy. Commissioner of Income Tax, Bharuch Circle, Bharuch

In the result, this appeal of the assessee is partly allowed

ITA 502/AHD/2015[2009-10]Status: DisposedITAT Surat24 Apr 2023AY 2009-10

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 143(3)Section 147Section 148Section 234BSection 234B(3)Section 254(1)Section 80Section 80I

facts and in the circumstances of the case and in law, the CIT(A) erred in not appreciating that once deduction under section 80IA was granted in the initial assessment year, it ought to be allowed in the subsequent years for the remaining period. Bharuch Enviro Infrastructure Ltd. Vs DCIT ... case and in law, the CIT(A) erred in holding that Incinerator Project 2 is not a separate undertaking and not eligible for deduction under section 80IA of the Act separately despite the fact that the said undertaking had started its operation from AY 2012-13 and the said issue

Bharuch Enviro Infrastructure Ltd., Ankleshwar vs. Dy. Commissioner of Income Tax, Bharuch Circle, Bharuch

In the result, this appeal of the assessee is partly allowed

ITA 501/AHD/2015[2008-09]Status: DisposedITAT Surat24 Apr 2023AY 2008-09

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 143(3)Section 147Section 148Section 234BSection 234B(3)Section 254(1)Section 80Section 80I

facts and in the circumstances of the case and in law, the CIT(A) erred in not appreciating that once deduction under section 80IA was granted in the initial assessment year, it ought to be allowed in the subsequent years for the remaining period. Bharuch Enviro Infrastructure Ltd. Vs DCIT ... case and in law, the CIT(A) erred in holding that Incinerator Project 2 is not a separate undertaking and not eligible for deduction under section 80IA of the Act separately despite the fact that the said undertaking had started its operation from AY 2012-13 and the said issue

Bharuch Enviro Infrastructure Ltd., Ankleshwar vs. Dy. Commissioner of Income Tax, Bharuch

In the result, this appeal of the assessee is partly allowed

ITA 500/AHD/2015[2007-08]Status: DisposedITAT Surat24 Apr 2023AY 2007-08

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 143(3)Section 147Section 148Section 234BSection 234B(3)Section 254(1)Section 80Section 80I

facts and in the circumstances of the case and in law, the CIT(A) erred in not appreciating that once deduction under section 80IA was granted in the initial assessment year, it ought to be allowed in the subsequent years for the remaining period. Bharuch Enviro Infrastructure Ltd. Vs DCIT ... case and in law, the CIT(A) erred in holding that Incinerator Project 2 is not a separate undertaking and not eligible for deduction under section 80IA of the Act separately despite the fact that the said undertaking had started its operation from AY 2012-13 and the said issue

Bharuch Enviro Infrastructure Limited, Ankleshwar vs. The Dy.CIT, Bharuch Circle, Bharuch

In the result, this appeal of the assessee is partly allowed

ITA 1935/AHD/2015[2009-10]Status: DisposedITAT Surat24 Apr 2023AY 2009-10

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 143(3)Section 147Section 148Section 234BSection 234B(3)Section 254(1)Section 80Section 80I

facts and in the circumstances of the case and in law, the CIT(A) erred in not appreciating that once deduction under section 80IA was granted in the initial assessment year, it ought to be allowed in the subsequent years for the remaining period. Bharuch Enviro Infrastructure Ltd. Vs DCIT ... case and in law, the CIT(A) erred in holding that Incinerator Project 2 is not a separate undertaking and not eligible for deduction under section 80IA of the Act separately despite the fact that the said undertaking had started its operation from AY 2012-13 and the said issue

Asst. Commissioner of Income Tax, CC-2, Surat vs. M/S. Hi-Tech Sweet Water Technologies (P) Ltd., Surat

In the result, appeal filed by the Revenue is dismissed

ITA 7/SRT/2023[2019-20]Status: DisposedITAT Surat30 Mar 2023AY 2019-20

Bench: SHRI PAWAN SINGH (Judicial Member), DR. A. L. SAINI (Accountant Member)

For Appellant: Shri Kiran K. Shah, CAFor Respondent: Shri Vinod Kumar, Sr- DR
Section 139Section 143(1)Section 143(3)Section 154Section 80I

Therefore, considering the findings of the Coordinate Bench of ITAT Surat in assessee’s own case (supra), the assessee is entitled to claim deduction under section 80IA of the Act. As we have noted above that the claim of deduction u/s 80IA of the Act was allowed to the assessee

The Assistant Commissioner of Income-Tax-2(1)Bhilai, Bhilai(Cg) vs. M/S Sms Shivnath Infrasstructure Pvt Ltd., Durg, Durg(Cg)

In the result, appeal of the revenue in ITA No

ITA 87/BIL/2017[2012-13]Status: DisposedITAT Raipur27 Mar 2023AY 2012-13

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita No.87/Rpr/2017 (ननधाारण वषा / Assessment Year :2012-2013) Acit-2(1), Bhilai Vs M/S Sms Shivnath Infrastructure Pvt Ltd.,Toll Plaza, Near Dhamdhanaka, Durg. Pan No. :Aadcs 2258 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. & आयकर अऩीऱ सं./Ita No.107/Rpr/2016 (ननधाारण वषा / Assessment Year :2012-2013) M/S Sms Shivnath Infrastructure Vs Pr.Cit-2, Raipur Pvt Ltd.,Toll Plaza, Near Dhamdhanaka, Durg. Pan No. :Aadcs 2258 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri Kapil Hirani, Adv. & MukeshFor Respondent: Shri Debashis Lahiri, CIT-DR
Section 115JSection 143(3)Section 250(4)Section 36Section 80ISection 80l

under section 80lA and was accordingly claimed in the return of income. 5. It is noteworthy to mention here that the claim of deduction under section 80IA is not in dispute and the Assessee has been claiming deduction under section 80lA for the past many years as well which

M/S Sms Shivnath Infrastructure Pvt Ltd, Durg(Cg) vs. The Pr. Commissioner of Income Tax-2, Raipur (Cg)

In the result, appeal of the revenue in ITA No

ITA 107/BIL/2016[2011-12]Status: DisposedITAT Raipur27 Mar 2023AY 2011-12

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अऩीऱ सं./Ita No.87/Rpr/2017 (ननधाारण वषा / Assessment Year :2012-2013) Acit-2(1), Bhilai Vs M/S Sms Shivnath Infrastructure Pvt Ltd.,Toll Plaza, Near Dhamdhanaka, Durg. Pan No. :Aadcs 2258 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. & आयकर अऩीऱ सं./Ita No.107/Rpr/2016 (ननधाारण वषा / Assessment Year :2012-2013) M/S Sms Shivnath Infrastructure Vs Pr.Cit-2, Raipur Pvt Ltd.,Toll Plaza, Near Dhamdhanaka, Durg. Pan No. :Aadcs 2258 Q (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri Kapil Hirani, Adv. & MukeshFor Respondent: Shri Debashis Lahiri, CIT-DR
Section 115JSection 143(3)Section 250(4)Section 36Section 80ISection 80l

under section 80lA and was accordingly claimed in the return of income. 5. It is noteworthy to mention here that the claim of deduction under section 80IA is not in dispute and the Assessee has been claiming deduction under section 80lA for the past many years as well which