11A) of the Act. Let us first examine the provisions of
Sec. 80IB(11A) of the Act.
Sec. 80IB (11A) ...... The amount of deduction ... this condition. The
memorandum appended to the Financial Bill by which Sec. 80IB(11A) was
amended show the Legislative intent is as under:
Tax holiday
However,
the assessment was completed after disallowing
deductions under sections 80IB(11) and 80IB(11A) of
the Income ... under sectio n assessment se ction
80IB(11) and second year of claiming deduction u/s
80IB(11A) of the Act. In the assessment orders
first examine the provisions of Sec.
80IB(11 A) of the Act .
Sec. 80IB (11A)...... The amount of deduction in a case of an undertaking ... this condition. The memorandum appended to the
Financial Bill by which Sec. 80IB(11A) was amended show the Legislative intent
is as under:
Tax holiday
Ahmedabad under Section 263 of
Income-tax Act holding that the assessee is eligible for deduction
under Section 80IB(11A) of Income
Ahmedabad under
Section 263 of Income-Tax Act holding that the assessee is eligible
for deduction under Section 80IB(11A) of Income
Fil Industries Ltd., Srinagar vs Assessee on 12 June, 2012
IN THE INCOME TAX APPELLATE
this appeal is with regard to
disallowance of deduction u/s. 80IB(11A) of the Income-tax Act,
1961.
3. Brief facts of the issue ... Anjali Warehouse and Balemia Warehouse. The assessee claimed
deduction u/s. 80IB(11A) of the Act in respect of profit derived
from Anjali Warehouse
relief to the assessee by
allowing the claim of deduction under sec. 80IB(11A)
of the IT Act, 1961 both on facts and circumstances ... undertaking' for the
purpose of claim of exemption under sec. 80IB(11A)
of the IT Act, 1961.
3. After hearing both the parties
that the incentive envisaged u/s. 80IB is a profit
linked incentive. Therefore, the incentive u/s. 80IA and 80IB is
linked to operational profit ... profit derived
from eligible business mentioned in subsection (3) to section 11A
of section 80IB . Each of the eligible business in the aforesaid
subsection constitute
claimed an amount of Rs.
11,01,597/- exempt u/s 80IB(11A) on account of
warehouse profit in the name of Srinathji
Warehousing Corporation ... expenditure
should not be considered unreasonable on
account of provision of Section 80IB(13) was
80IA(8) and 80IA(10) of the Income
