therefore, at the stage of sub-
section(3) of section 80HHC effect
of sub-section(9) of section 80IA
would apply. It is true that ... section' can be
used to interpret that section
80HHC of the Act can have no
effect of sub-section (9) of
section 80IA
section (3) of
section 143 or this section has been made for the relevant
assessment year, no action shall be taken under this section after ... return under section 139 or in
response to a notice issued under sub-section (1) of section 142
or section 148 or to disclose fully
therefore, at
the stage of sub-section(3) of section
80HHC effect of sub-section(9) of
section 80IA would apply. It is true
that ... section' can be used to interpret
that section 80HHC of the Act can have
no effect of sub-section (9) of
section 80IA
allowable under sections 30 to 43D
of the Act or not, the quantum of
15 (2009) 318 ITR 352 deduction
under section 80IA ... exemption claimed
under section 15C(2)(i) of the Income
Tax Act,1922, which is peri materia to
section 80IA of the Act, has held
case is covered by sub-
clause (b) of sub- section 12 of section
80IA of the Act,1961.
7.5 It was submitted that the
deduction ... 80IA of the
Act.
8.5 It was submitted that sub-section
(12) of section 80IA of the Act provides
that any undertaking of an Indian
under Section 263 of the Act, the PCIT took a view that
the respondent/assessee was not eligible to any deduction under Section
80IA ... this appeal, namely
the scope of Section 263 of the Act and scope of Section 80IA of the Act.
According to the appellant/revenue, PCIT
learned tribunal setting aside the disallowance of deduction claimed under
Section 80IA(4) of the Income Tax Act, 1961 (the Act). The facts which ... order dated 30.10.2019 passed under Section
92CD(3) of the Act, disallowed the deduction claimed under Section 80IA(4)
of the Act. The assessee moved
learned tribunal setting aside the disallowance of deduction claimed under
Section 80IA(4) of the Income Tax Act, 1961 (the Act). The facts which ... order dated 30.10.2019 passed under Section
92CD(3) of the Act, disallowed the deduction claimed under Section 80IA(4)
of the Act. The assessee moved
submit that a substantial expansion
would qualify for deduction under
section 80IA of the Act.
13. On the other hand, learned
Senior Standing Counsel ... exemption claimed
under section 15C(2)(i) of the Income
Tax Act,1922, which is peri materia
to section 80IA of the Act, has held
question of law with regard to deleting
disallowance made under Section 80IA(4) of the
Act on the ground that assessee is not a
contractor ... infrastructure facilities"
3.13. Sub-clause 1 of Sub- section 4 of
Section 80IA of the Act provides that
Section 80IA applies to any enterprise