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HC dismissed Revenue's appeal, upholding the CIT(A) and ITAT orders allowing assessee's deduction under s.10A for its STP unit. HC held that the undertaking was not formed by "splitting up or reconstruction of a business already in existence" within the meaning of s.10A(2)(ii). The appellate authorities had recorded fact-based findings that the new unit involved substantial fresh investment and independent undertaking, despite being engaged in similar activity, and had correctly applied the governing legal principles. HC found no perversity in these factual findings and concluded that no substantial question of law arose for consideration. Consequently, the assessee's s.10A claim stood affirmed and the Revenue's appeal was rejected.
HC dismissed Revenue's appeal, upholding the CIT(A) and ITAT orders allowing assessee's deduction under s.10A for its STP unit. HC held that the undertaking was not formed by "splitting up or reconstruction of a business already in existence" within the meaning of s.10A(2)(ii). The appellate authorities had recorded fact-based findings that the new unit involved substantial fresh investment and independent undertaking, despite being engaged in similar activity, and had correctly applied the governing legal principles. HC found no perversity in these factual findings and concluded that no substantial question of law arose for consideration. Consequently, the assessee's s.10A claim stood affirmed and the Revenue's appeal was rejected.
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