TMI Blog2014 (4) TMI 561X X X X Extracts X X X X X X X X Extracts X X X X ..... rofit center but a cost saving exercise undertaken in terms of subsection (4) of Section 80IA ?" - Income Tax Appeal No. 6070 of 2010 - - - Dated:- 2-4-2014 - S. C. Dharmadhikari And G. S. Kulkarni,JJ. For the Appellants: Mr. Vimal Gupta, Vipul Arun Bajpayee For the Respondents : Mr. J. D. Mistry, A. K. Jasaniappeal JUDGMENT P. C. 1 Having heard Mr.Gupta, learned senior ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ad that Rail system is a profit center. That, Rail system has been established and that all requirements of subsection (4) of Section 80IA are fulfilled, is not in dispute. That the Rail system is not to be donated or given to the railways for the benefit of the public. So long as the Rail system is operated and maintained which results in saving of transportation costs for the assessee and that a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... enough. The invoices are not raised and, therefore, by that itself a conclusion cannot be drawn that the rail system is not a profit center but cost saving one. Something more is required to be brought on record so as to enable the assessee to claim the benefit. 4 After hearing the counsel at some length and perusing with their assistance the orders passed by the Commissioner of Income Tax (App ..... X X X X Extracts X X X X X X X X Extracts X X X X
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