TMI Blog2011 (7) TMI 1262X X X X Extracts X X X X X X X X Extracts X X X X ..... This appeal by the Revenue is directed against the order of the Ld. Commissioner of Income Tax (Appeals) dated 04.11.2010 pertaining to assessment year 2007-08. 2. The issue raised is that on the facts and circumstances of the case, the Ld. Commissioner of Income Tax (Appeals) has erred in law and on facts in allowing the appeal of the assessee in respect of the issue of claim of deductio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... given to the assessee to obtain the certificate which is not sufficient, we are of the considered opinion that additional evidence was rightly admitted by the Ld. Commissioner of Income Tax (Appeals). In view of this, ground no. 1 of the revenue is rejected. Regarding ground no. 2 of the revenue, we find that Ld. Commissioner of Income Tax (Appeals) has reproduced the contents of letter dated 12. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d under the LOP. This is being issued with the approval of competent authority. (M.P. Dubey) Jt. Director 6. After reproducing the contents of this letter dated 12.3.08, it has been noted by the Ld. Commissioner of Income Tax (Appeals) that as per this letter of STPL, manufacture of computer software includes software development and IT enabled services, which is the activity of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... al had decided the issue in favour of the assessee and the Ld. Commissioner of Income Tax (Appeals) has followed the same. Hence, we do not find any infirmity in the order of the Ld. Commissioner of Income Tax (Appeals). Accordingly, we uphold the same. 7. In the result, the appeal filed by the revenue stands dismissed. Order pronounced in the open court on 28/7/2011. - - TaxTMI - T ..... X X X X Extracts X X X X X X X X Extracts X X X X
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