Section 80IB(10) deduction upheld where the work contract objection was already settled in the assessee's favour.

Deduction under section 80IB(10) was held available to the assessee despite the revenue's contention that the arrangement with end users was a work contract. The Court treated the issue as no longer open because the same question had already been decided in the assessee's favour and that view had attained finality. In that settled position, no further merits-based examination was undertaken, and the issue was answered in favour of the assessee and against the revenue.

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Issues: Whether the assessee was entitled to deduction under section 80IB(10) of the Income-tax Act, 1961 despite the contention that the arrangement with the end users amounted to a work contract.

Analysis: The issue was treated as no longer open for consideration because the same question had already been decided by the Court in favour of the assessee and had attained finality. In view of that settled position, no further merits-based examination was required.

Conclusion: The question was answered in favour of the assessee and against the revenue.

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