Section 80IA deduction dispute resolved by binding precedent, with no substantial question of law arising.

Section 80IA deduction was considered in relation to activities said not to fall within clause (d) of the Explanation to section 80IA(4). The Court noted that the legal question had already been settled against the Revenue by binding decisions of the Court and the Supreme Court, so the proposed issue did not raise any substantial question of law under section 260A. The result was that the claim was treated as allowable in favour of the assessee and against the Revenue.

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Issues: Whether the assessee was entitled to deduction under section 80IA of the Income-tax Act, 1961 despite the activities not falling within clause (d) of the Explanation to section 80IA(4) of the Income-tax Act, 1961.

Analysis: The issue was already concluded against the Revenue by binding decisions of the Court and the Supreme Court on the same legal question. In view of those decisions, the proposed question did not give rise to any substantial question of law for consideration under section 260A of the Income-tax Act, 1961.

Conclusion: The issue was answered in favour of the assessee and against the Revenue.

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