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2023 (7) TMI 681 - AT - Income TaxDeduction u/s. 80IA(4) - infrastructure activities with respect to CFS and ICDs - HELD THAT:- As respectfully following the decision in the assessee’s own case for the AY 2011-12 [2015 (12) TMI 365 - ITAT VISAKHAPATNAM] as well as the ratio laid down in the case of M/s. Container Corporation [2018 (5) TMI 359 - SUPREME COURT] and M/s. AL Logistics (P) Ltd [2015 (1) TMI 401 - MADRAS HIGH COURT] decision of Continental Warehousing Corporation [2015 (5) TMI 656 - BOMBAY HIGH COURT], as having regard to the provisions of the Customs Act, the communication issued by the Central Board of Excise and Customs as well as the Ministry of Commerce and Industry, the object of including “inland port” as an infrastructure facility and also that customs clearance also takes place in the inland container depot, the assessee’s claim that the inland container depots were inland ports under Explanation (d) to sec. 80IA(4) required to be upheld - we find no infirmity in the order of the Ld. CIT(A) while allowing the assessee’s appeal.
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