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    <title>2013 (6) TMI 70 - DELHI HIGH COURT</title>
    <link>https://www.taxtmi.com/caselaws?id=234245</link>
    <description>The HC upheld the ITAT&#039;s decision allowing deductions under Section 80-I for Unit Nos. 2 and 3, rejecting the revenue&#039;s claim that these units were formed by splitting the existing Unit No. 1. The court found no evidence of asset transfer or discontinuation of Unit No. 1&#039;s activities, confirming that Units 2 and 3 were additional undertakings. The conditions under Section 80-I(2)(i) were not violated as the new units were not formed by reconstruction or splitting of the existing business. Further, since the AO had allowed the deduction for three prior assessment years, he could not deny it subsequently without reopening those years. The relief was accordingly maintained in favor of the assessee.</description>
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    <pubDate>Fri, 31 May 2013 00:00:00 +0530</pubDate>
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      <title>2013 (6) TMI 70 - DELHI HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=234245</link>
      <description>The HC upheld the ITAT&#039;s decision allowing deductions under Section 80-I for Unit Nos. 2 and 3, rejecting the revenue&#039;s claim that these units were formed by splitting the existing Unit No. 1. The court found no evidence of asset transfer or discontinuation of Unit No. 1&#039;s activities, confirming that Units 2 and 3 were additional undertakings. The conditions under Section 80-I(2)(i) were not violated as the new units were not formed by reconstruction or splitting of the existing business. Further, since the AO had allowed the deduction for three prior assessment years, he could not deny it subsequently without reopening those years. The relief was accordingly maintained in favor of the assessee.</description>
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      <pubDate>Fri, 31 May 2013 00:00:00 +0530</pubDate>
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