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11.2 We find a somewhat similar issue had come up before the Hon'ble Madras High Court in the case of CIT Vs. Heartland KG Information Ltd.(Supra). In that case, the assessee was an industrial undertaking engaged in Medical Transcription business. There was another undertaking K which got approval as 100% EOU from STPI and started its new business of medical transcription during F.Y. 1999 -2000. It also had another undertaking engaged in the business of development of software exported outside India. In respect of business income earned from export the said undertaking claimed exemption u/s.10A of the I.T. Act. In July, 2001 the company K transferred its entire undertaking engaged in the export business of medical transcription along with all transcriptions, contracts, books, 20 records, all rights, all permits, warranties including computer software and export obligation to the assessee company. The transfer was recognised and allowed by the STPI. The assessee claimed deduction u/s.10B in respect of income from export. However, the AO rejected the claim on the ground that approval obtained from STPI for purpose of section 10B would not be sufficient to grant relief. According to him, the transfer was only related to machinery and thus the claim could not be sustained. He however granted deduction u/s.80HHE on alternative claim of the assessee. In appeal the Ld.CIT(A) referring to CDBT Circular File No.15/5/63(IT)(A-1) held that the benefit with the vendor company in respect of individual undertaking engaged in the manufacture of articles could be claimed by successor company for the remaining tax holiday period since the entire undertaking of the business of medical transcription was transferred to the assessee. Thus, the assessee would be entitled to have the benefit u/s10A of the Act for the remaining period. He therefore held that relief u/s.80HHE would be available to the assessee. The Hon'ble Tribunal affirmed the order of the CIT(A). On further appeal by the Revenue, the Hon'ble High Court dismissed the appeal filed by the Revenue and upheld the order of the Tribunal. While doing so, the Hon'ble High Court held that even assuming for a moment that the assessee has not referred to the section correctly, the fact remains that if the claim could be favourably considered under any of those special deduction provisions and all the conditions specified therein being satisfied 21 there is no justifiable ground exist for the revenue to contend that the assessee shall not be entitled to have the benefit of section 10A of the I.T. Act.