9911796707
TMI Blog2012 (6) TMI 112X X X X Extracts X X X X X X X X Extracts X X X X ..... appeal by the Revenue under Section 260A of the Income Tax Act, 1961 impugns the order dated 28th July, 2011 passed by the Income Tax Appellate Tribunal (for short, the tribunal) in the case of Annik Technologies Pvt. Ltd. The appeal pertains to the assessment year 2007-08. 2. Learned counsel for the Revenue has raised two contentions before us. These have been dealt with separately. 3. It is su ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... refore, on this aspect, no substantial question of law arises out of the impugned order dated 28th July, 2011. 4. The second contention raised by the learned counsel for the Revenue relates to interpretation of Section 10A(2)(i) of the Act, which reads as under:- "10A. Special provision in respect of newly established undertakings in free trade zone, etc.? x x x x x x (2) This section applies ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... respondent-assessee was entitled to benefit under Section 10A in case any of the clauses (a), (b) and (c) are applicable. What is contended and argued before us is that clause (c) applicable w.e.f. 1st April, 2001 had the effect of overriding clauses (a) and (b). 6. This is not correct as the CBDT had issued Circular No. 794 dated 9th August, 2000 reported in (2000) 245 ITR (St.) 21, in which in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y exclusive and operate in their own field. 8. In the present case, STP registration was granted to the partnership firm-Annik Technologies by the Directorate of Software Technologies Parks of India. In September, 2005, pursuant to an agreement, the entire business was transferred to the respondent-company. The name of the respondent-company was substituted in the STP registration record. The uni ..... X X X X Extracts X X X X X X X X Extracts X X X X
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