2011 (8) TMI 738

Head Note / Extract:
Deduction under 80-IC - Proprietorship Converted into Partnership Concern - Revenue contended deduction available only when an Indian Company is taken over by another Indian Company - Held That:- Benefit of 80IC cannot be denied only on the ground that section 80-IA embraces only cases of amalgamation or demerger of Indian Company. - Further 80IC postulates that undertaking eligible for deduction under the section is not formed by splitting up or reconstruction of a business already in existence. Section 80IC: deduction upon the undertaking and not the owner. When such conditions are fulfilled successor will get benefit for the unexpired period.