deleting the disallowance of Rs.2,96,26,413/- under section 80IC
ignoring the fact that transaction was sham and purpose of
following the circuitous ... Systems
(India) Ltd. was to get the benefit of deduction under section 80IC?
2.2 Whether the ld. ITAT erred in upholding the decision
eligibility of
benefits that were claimed by the assessee under Section 80IC of the
Act.
3. Aggrieved by the order of assessment as framed ... ITAT. We
note that the CIT(A), while dealing with the Section 80IC question,
had rendered the following pertinent observations
Whether the order of the AO allowing deduction under section
80IC in contravention to provision of search 80IA(7) read with
section 80IC can legally ... case of eligibility of the assessee who claimed deduction under
Section 80IC of the Income Tax Act, 1961 ["Act"] had not been
questioned
case, the Ld.
ITAT has erred in holding that deduction u/s 80IC based on Sales
Tax/ VAT/ Excise documents ignoring the fact that ... case, the Ld.
ITAT has erred in holding that deduction u/s 80IC of the Act can
be allowed from profit derived at the eligible
department."
5. Insofar as questions pertaining to Sections 80IB and 80IC of the
Act are concerned, Mr. Chawla could not question or doubt
Kala Amb unit as well as the deduction
claimed u/s 80Ic were left untouched. There is no bar in
arriving at different conclusion than
