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Issues: (i) Whether expenditure on development of toilet blocks, bus shelters and foot over bridges qualified as deduction for infrastructure facility under section 80IA(4) of the Income-tax Act, 1961; (ii) Whether expenditure relatable to the period prior to assessment year 2004-05 was allowable.
Issue (i): Whether expenditure on development of toilet blocks, bus shelters and foot over bridges qualified as deduction for infrastructure facility under section 80IA(4) of the Income-tax Act, 1961.
Analysis: The issue was treated as covered by an earlier decision holding that construction of foot over bridges and bus shelters by an advertising concern constituted infrastructure development within the statutory explanation to section 80IA(4). The decision was followed and the claim for deduction was sustained.
Conclusion: The issue was answered against the Revenue and in favour of the assessee.
Issue (ii): Whether expenditure relatable to the period prior to assessment year 2004-05 was allowable.
Analysis: The issue was held to be covered by an earlier binding decision and by the assessee's own prior assessment year, where the same question had been decided in favour of the assessee.
Conclusion: The issue was answered against the Revenue and in favour of the assessee.
Final Conclusion: The appeal failed and the questions of law were decided against the appellant-revenue, leaving the assessee's relief intact.
Ratio Decidendi: Construction of specified public utility structures by an eligible assessee can constitute infrastructure development for deduction under section 80IA(4), and a covered prior-period expenditure issue follows the binding precedent applicable to the assessee's own case.
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