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HC ruled against assessee's claim for Section 80IA benefits regarding cargo terminal operations. Court determined that DIAL, being a private consortium operating under AAI concession, does not qualify as a statutory body, government entity, or local authority under Section 80IA(4). Despite cargo terminal being considered an infrastructure facility integral to airport operations, the fundamental requirement of agreement with government/statutory bodies was not met. The concession granted by DIAL to assessee failed to satisfy Section 80IA(4) prerequisites. PCIT's exercise of revisionary powers under Section 263 was upheld, reversing Tribunal's earlier interference. Court emphasized that DIAL's operation under AAI Act does not elevate it to statutory body status.
HC ruled against assessee's claim for Section 80IA benefits regarding cargo terminal operations. Court determined that DIAL, being a private consortium operating under AAI concession, does not qualify as a statutory body, government entity, or local authority under Section 80IA(4). Despite cargo terminal being considered an infrastructure facility integral to airport operations, the fundamental requirement of agreement with government/statutory bodies was not met. The concession granted by DIAL to assessee failed to satisfy Section 80IA(4) prerequisites. PCIT's exercise of revisionary powers under Section 263 was upheld, reversing Tribunal's earlier interference. Court emphasized that DIAL's operation under AAI Act does not elevate it to statutory body status.
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