STPI approval supports section 10B deduction where export-oriented status and past acceptance were not displaced by contrary material.

STPI approval treating the undertaking as a 100 per cent export oriented unit was accepted as sufficient for section 10B eligibility, and the assessee's claim was also supported by acceptance in earlier years. No material was produced to displace the finding that the approval was valid or that the deduction was otherwise inadmissible. On that record, the appellate view in favour of the assessee was left undisturbed and the Revenue's challenge failed.

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Issues: Whether the assessee was entitled to deduction under section 10B of the Income-tax Act, 1961 on the strength of STPI approval as a 100 per cent export oriented undertaking, and whether the Revenue had shown any basis to deny the deduction.

Analysis: The approval granted by STPI for the undertaking as a 100 per cent export oriented unit was treated as sufficient for the purposes of section 10B, and the record showed that the claim had been accepted in earlier years as well. No material was brought to dislodge the finding that the assessee held a valid approval and was eligible for the deduction. In these circumstances, there was no reason to disturb the appellate finding in favour of the assessee.

Conclusion: The assessee was held entitled to deduction under section 10B, and the Revenue's challenge failed.

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