Section 80-I deduction upheld where the industrial undertaking satisfied the workforce condition on the Tribunal's findings.

Section 80-I deduction was held allowable on the facts found by the Tribunal because more than twenty persons were working under the assessee's control in the industrial undertaking. The Gujarat HC noted that the issue had already been decided in the assessee's own case, so the question was no longer res integra. The legal position applied was that the statutory condition for the deduction was satisfied on the Tribunal's factual findings, and the deduction was therefore upheld in favour of the assessee.

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Issues: Whether the assessee was entitled to deduction under Section 80-I of the Income-tax Act, 1961 on the facts found by the Tribunal.

Analysis: The issue had already been decided in the assessee's own case, where it was held that the Tribunal was right in directing allowance of the deduction because more than twenty persons were working under the assessee's control in the industrial undertaking. The question, therefore, no longer survived as a res integra.

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

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