The assessee was a public limited company which was wholly owned by the Government of Karnataka and was engaged in the activity of distribution of electricity. The assessee filed the return of income for the assessment year 2005-06 claiming deduction of Rs. 141,84,44,170 under section 80-IA(4)(iv)(c) . The Assessing Officer  disallowed which was confirmed by CIT (A) and Tribunal . On appeal to the High Court the assessee submitted that its case fell within the third category of undertakings and therefore, the amount undertaken towards renovation and modernization had to be considered. Alternatively, it submitted that capital work-in-progress was to be included and should not be restricted only to those amounts which were capitalized in books and substantial renovation and modernization could be at any time during the period beginning on April 1, 2004 and ending on March 31, 2006. It contended that it had undertaken substantial renovation and modernization of existing lines which was more than 50 per cent. of the book value of assets as on April 1, 2004 under the Explanation to section 80-IA(4)(iv)(c) . Allowing the appeal the Court held that  the assessee had undertaken substantial renovation and modernization of existing lines which was more than 50 per cent. of the book value of the assets as on April 1, 2004 under the Explanation to section 80-IA(4)(iv)(c) of the Act. Thus, it could safely be inferred that the assessee had undertaken the work towards renovation and modernization of existing transmission or distribution lines. The assessee was entitled to deduction under section 80-IA(4) . relied on the  Circular dated July 15, 2005 ([2005] 276 ITR (St.) 151)  (AY. 2005-06).