https://www.taxtmi.com/caselaws?id=259199 The Tribunal ruled in favor of the assessee, holding that the claim for deduction under section 80IA(4) fell under clause (a) of the Explanation, as the project was specifically for a toll road with controlled access and exit points. The deduction was deemed eligible from the commencement of business operations in 2007, rejecting the CIT's argument that it should only be available once the infrastructure facility began operating in 2012. The Tribunal found the AO's decision reasonable and sustainable, emphasizing that the CIT's invocation of section 263 lacked a decisive conclusion and revision on issues not mentioned in the notice was deemed invalid. The CIT's order was quashed, and the assessee's appeal was allowed. en-us Mon, 13 Apr 2015 00:00:00 +0530 Mon, 04 May 2015 06:42:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=259199 The Tribunal ruled in favor of the assessee, holding that the claim for deduction under section 80IA(4) fell under clause (a) of the Explanation, as the project was specifically for a toll road with controlled access and exit points. The deduction was deemed eligible from the commencement of business operations in 2007, rejecting the CIT's argument that it should only be available once the infrastructure facility began operating in 2012. The Tribunal found the AO's decision reasonable and sustainable, emphasizing that the CIT's invocation of section 263 lacked a decisive conclusion and revision on issues not mentioned in the notice was deemed invalid. The CIT's order was quashed, and the assessee's appeal was allowed. Case-Laws Income Tax Mon, 13 Apr 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=259199