Section 10A exemption followed prior year ruling where no distinguishing facts were shown, sustaining relief to the assessee.

Section 10A exemption was upheld because the same issue had already been decided in the assessee's own case for an earlier year and that view had been affirmed by the High Court. As no material factual distinction was shown for the year under review, the Tribunal followed the earlier on consistency grounds and sustained the relief granted to the assessee. The Revenue's challenge therefore failed.

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Issues: Whether the assessee was entitled to exemption under section 10A of the Income-tax Act, 1961 for the assessment year 2008-09.

Analysis: The issue had been decided in the assessee's own case for an earlier assessment year, and that decision had been affirmed by the High Court. No material distinction in facts for the present year was shown to justify a different view.

Conclusion: The exemption under section 10A was upheld and the revenue's challenge failed.

Final Conclusion: The appellate order granting relief to the assessee was sustained and the revenue appeal did not succeed.

Ratio Decidendi: Where the same exemption issue has been decided in the assessee's own case and affirmed on appeal, and no distinguishing facts are shown, consistency requires following that decision.

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