2026 (4) TMI 566

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....is matter is covered in favour of the assessee by an earlier order of this Court in Commissioner of Income Tax, Chennai v. Tidel Park Ltd. [430 ITR 214]. The substantial questions of law admitted on 21.07.2014 are as follows: '1.Whether on the facts and in the circumstances of the case, the Income Tax Appellate Tribunal was right in law in holding that the assessee is not entitled to deduction under Section 80IA in respect of income from Operation and Maintenance Charges, interest income, income from revenue sharing from lessee, other income, income from auditorium and rent others? 2.Whether on the facts and circumstances of the case, the Tribunal was right in law in restricting the claim of deduction under Section 80IA wh....

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....as below: '6. Though the learned counsel for the Revenue Mr.Karthik Ranganathan, sought to urge before us that the development of I.T. Park was not the main business activity of the Assessee company, he failed to establish his contention with the help of any relevant evidence, including the memorandum of association of the company or any other relevant documents. 7. On the contrary, we found from the discussion in the order of the Commissioner of Income-tax (Appeals) as well as the learned Tribunal that the Assessee has not only shown part of its income as income from other property, but has only allowed the claim of the Assessee to tax the income from the software companies in the form of lease rentals from Olympia Tech P....