TMI Blog2019 (2) TMI 645X X X X Extracts X X X X X X X X Extracts X X X X ..... issue raised in the present appeal is similar to the issue before the Tribunal in earlier years and following the same parity of reasoning, we hold that the assessee is entitled to claim the deduction under section 80IA(4) of the Act. Thus, the grounds of appeal raised by Revenue are dismissed. - ITA No.2864/PUN/2016 - - - Dated:- 11-2-2019 - Ms. Sushma Chowla, JM And Shri D. Karunakara Rao, AM ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ) has erred in relying on the decision of Container Corporation of India Ltd. Vs ACIT (2012) 346 ITR 140 (Delhi) which is misplaced. 03. For the facts and such other reasons as may be urged at the time of hearing, the order of the Ld. Commissioner of (Appeals), Pune may be vacated and that of the Assessing Officer be restored. 3. The learned Authorized Representative for the assessee at t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... st. The Assessing Officer disallowed the claim of assessee under section 80IA(4) of the Act on the ground that the assessee has failed to furnish a certificate from the concerned port authorities certifying that the structure at the port for storage, loading and unloading etc. formed part of Port. 7. We find that similar claim of deduction under section 80IA(4) of the Act was denied to the asse ..... X X X X Extracts X X X X X X X X Extracts X X X X
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