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19. In the present case, since the requirements of Section 80-IA(4) are satisfied, the assessee is entitled to the benefit of deduction under Section 80-IA(4). The respondent assessee is entitled to the deduction in respect of all assessment years for which deduction under Section 80-IA(4) has been denied.

20. The questions of law are answered against the revenue and in favour of the assessee. All the appeals are dismissed.



              (B.S.Walia)       (Ramalingam Sudhakar)
                 Judge                    Judge
Jammu,
27.09.2016
Varun