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Commissioner of Income-tax-I, Chandigarh Versus Mega Packages - 2011 (8) TMI 738 - PUNJAB AND HARYANA HIGH COURT

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.



 

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