TaxTMI 
TaxTMI 
2020 (10) TMI 1162
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....passed by the Income Tax Appellate Tribunal, Madras 'A' Bench, Chennai in ITA Nos.2573/Chny/2017; 2574/Chny/2017 dated 16.03.2018 for the Assessment Years 2013-2014 and 2014-2015 respectively. 2. The revenue has raised the following Substantial Questions of Law for consideration: "1. Whether the Appellate Tribunal was right and justified in holding that Container Freight Station constitutes an 'inland port' and is therefore entitled for deduction under Section 801A(4) of the Income Tax Act? 2. Whether the Appellate Tribunal was correct and justified in holding that assessee is eligible for deduction u/s 801A(4) even though it had not entered into agreement with Central Government, State Government, local authority or a....
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....r the assessment years, 2010-11 to 2011-12 were challenged before the Tribunal by the Revenue. The Appellate Tribunal rejected the contention of the Revenue and dismissed the same. Against the order of the Appellate Tribunal only, present appeals have been filed. 3. These appeals were admitted on 27.03.2018 on the following substantial question of law : "Whether Container Freight Station (CFS) is part of Inland Port and therefore, an infrastructure facility as defined in the Explanation to Section 80IA (A) (i) of the Income Tax Act, 1961 and entitled to deduction under the said Section?" 4. When the matter is called today Mr.Narayanaswamy, learned Senior Standing Counsel appearing on behalf of the appellant would submit that the su....
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....n the country as these depots acts as a facilitator and reduce inconvenience to the person who wishes to export or import but place of his business is situated in a land locked area i.e., away from the sea. These depots reduce the inconvenience in import and export in the sense that it reduces the bottlenecks that are arising out of handling and customs formalities that are required to be done at the sea ports by allowing the same to be done at these depots only that are situated near to them. The term ICDs was inserted in 1983 under Section 2 (12) of the Customs Act, 1962 which defines 'customs port' and by the provisions of Section 7(1)(aa) of the Customs Act,1962 power has been given to the Central Board of Excise and Custom(CBEC) to....