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Commissioner Of Income Tax vs M/S. Pruthvi Brokers & Shareholders on 21 June, 2012

As such the assessee cannot be granted deduction u/s. 10B of the Act. In other words, so long as the assessee has not made available the audit report and other documents pointed out by the CIT(A) in terms of section 10B of the Act before framing of the assessment, the claim of deduction u/s. 10B cannot be granted. Further, the assessee cannot claim the exemption u/s. 10B without withdrawing the claim which was already granted u/s. 80HHC of the Act. The judgment of the Bombay High Court relied on by the assessee in the case of CIT vs. Pruthvi Brokers and Shareholders Pvt. Ltd. (349 ITR 336) was delivered on different set of facts and cannot be applied to the facts of the present case. Being so, we do not find any infirmity in the order of the CIT(A) in rejecting the claim of deduction u/s. 10B of the Act and the same is confirmed. This ground of appeal of the assessee is dismissed.
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