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2021 (7) TMI 244 - AT - Income TaxDeduction u/s 10A - Software Technology Parks of India (STPI) Unit - splitting up or reconstruction of the existing business - voilation of the conditions stipulated u/s. 10A - HELD THAT:- We find that the Tribunal had extensively examined the issue in its order placing reliance on the decision in the case of CIT vs. Expert Outsource (P) Ltd. [2011 (3) TMI 1428 - KARNATAKA HIGH COURT] and had also analyzed the CBDT Circular No. 1/2005 and thereafter, had provided relief to the assessee. In fact, the Hon'ble Karnataka High Court in its decision (supra.) itself has analyzed the applicability of CBDT Circular No. 1/2005 dated 06.01.2005 and that it had granted certain benefits u/s. 10B of the Act and though the circular was in the context of section 10B, the ratio of the circular equally applies to Section 10A - Appeal of the Revenue is dismissed.
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