STPI approval treated as sufficient for export undertaking deduction, making denial for lack of separate board approval unsustainable.

STPI approval was treated as sufficient to satisfy the requirement of a hundred per cent export oriented undertaking for deduction under section 10B. The Tribunal's reasoning, as noted in the text, relied on consistent allowance of the benefit in earlier and later years and on co-ordinate bench views that STPI approval meets the statutory approval requirement. On that basis, denial of the deduction only because separate board approval was not obtained was considered unsustainable, and the disallowance was deleted.

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Issues: Whether the assessee was entitled to deduction under section 10B on the basis of approval granted by Software Technology Parks of India as a hundred per cent export oriented undertaking.

Analysis: The assessee was registered with STPI and had been consistently allowed the benefit in earlier and later assessment years. The Tribunal relied on co-ordinate bench decisions holding that STPI approval is a competent approval for the purpose of section 10B and that such approval satisfies the statutory requirement for a hundred per cent export oriented undertaking. In view of the consistent treatment in surrounding years and the judicial view that STPI approval is sufficient, the denial of deduction solely for want of a separate board approval was not sustainable.

Conclusion: The assessee was entitled to deduction under section 10B, and the disallowance was deleted in favour of the assessee.

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