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HC reversed Tribunal's ruling on Section 80IC deduction eligibility. Unlike Section 80IA, Section 80IC(2)(b)(ii) does not mandate agreement with Central/State Government or local authority as prerequisite for tax benefits. Court distinguished between Section 80IC(2)(a), requiring compliance with Central Government schemes, and 80IC(2)(b), which only necessitates manufacturing specified items in designated states within prescribed periods. Tribunal erroneously applied Rule 18BBB and Form 10CCB requirements, which cover multiple provisions (80I, 80IA, 80IB, 80IC). Additionally, Tribunal's examination of abnormal profits under Section 80IA(8) and 80IA(10) was procedurally improper as these issues weren't previously raised before AO or CIT(A). Appeal allowed in favor of assessee.
HC reversed Tribunal's ruling on Section 80IC deduction eligibility. Unlike Section 80IA, Section 80IC(2)(b)(ii) does not mandate agreement with Central/State Government or local authority as prerequisite for tax benefits. Court distinguished between Section 80IC(2)(a), requiring compliance with Central Government schemes, and 80IC(2)(b), which only necessitates manufacturing specified items in designated states within prescribed periods. Tribunal erroneously applied Rule 18BBB and Form 10CCB requirements, which cover multiple provisions (80I, 80IA, 80IB, 80IC). Additionally, Tribunal's examination of abnormal profits under Section 80IA(8) and 80IA(10) was procedurally improper as these issues weren't previously raised before AO or CIT(A). Appeal allowed in favor of assessee.
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