1986 (7) TMI 57

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....Act, 1961 (hereinafter referred to as "the Act"), the Income-tax Appellate Tribunal, Indore Bench, Indore, has referred the following question of law to this court for its opinion: "Whether, on the facts and in the circumstances of the case, the Tribunal was justified in law in upholding the decision of the Commissioner of Incometax (Appeals) allowing deduction under section 80J of the Act to t....

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....al before the Tribunal. The Tribunal upheld the order of the Commissioner of Income-tax (Appeals) and dismissed the appeal. Hence, at the instance of the Revenue, the aforesaid question of law has been referred to this court for its opinion. At the time of hearing, learned counsel for the Revenue conceded that the matter was covered by a decision of this court in CIT v. Sanghi Beverages (Pvt.) ....

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....amount of deduction on time basis, with reference to the working of the industrial undertaking The provisions of section 80J of the Act which are intended to encourage the setting up of a new industrial enterprise have to be construed liberally. Even if a new undertaking has functioned for only a part of an accounting year, the deduction has to be allowed to the full extent and the percentage cann....