https://www.taxtmi.com/caselaws?id=465552 Deduction under s. 80ID was denied on the ground that the "new" hotel was formed by transfer/reconstruction of an existing hotel business rather than being a qualifying new undertaking. The HC held that uncontroverted assessment-record facts showed an existing hotel was operational during earlier FYs and was later leased and sold, evidencing continuity and transfer of the same business; therefore the Tribunal's finding that the claim was barred as a transfer of an existing business was a pure factual determination. As the assessee failed to demonstrate perversity in the concurrent factual findings of the AO, CIT(A) and Tribunal, the questions were answered against the assessee and the appeal was dismissed. en-us Mon, 03 Mar 2025 00:00:00 +0530 Tue, 30 Dec 2025 19:04:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465552 Deduction under s. 80ID was denied on the ground that the "new" hotel was formed by transfer/reconstruction of an existing hotel business rather than being a qualifying new undertaking. The HC held that uncontroverted assessment-record facts showed an existing hotel was operational during earlier FYs and was later leased and sold, evidencing continuity and transfer of the same business; therefore the Tribunal's finding that the claim was barred as a transfer of an existing business was a pure factual determination. As the assessee failed to demonstrate perversity in the concurrent factual findings of the AO, CIT(A) and Tribunal, the questions were answered against the assessee and the appeal was dismissed. Case-Laws Income Tax Mon, 03 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465552