Allowing the appeal the Tribunal held  that the benefit of deduction was given by the Act to the individual undertaking. The deduction of the profits and gains of the business of an eligible undertaking had to be made independently and before giving effect to the provisions for set off and carry forward contained in sections 70, 72 and 74. The Department was not right in law in holding that the assessee was not entitled to the benefit of deduction given by the Act under section 10A / 10B as amended by the Finance Act, 2003 with retrospective effect from April 1, 2001 qua individual eligible undertaking.( AY. 2011-12)