Assessee is engaged in business of providing telecommunication and related support services. Since year 2003, it was dealing in Internet Protocol-Virtual Private Network (IP-VPN) services license and in year 2006, Department of Telecommunication (DoT) granted National Long Distance-International Long Distance (NLD-ILD) license.It filed return of income declaring its total income as nil on basis of deduction under section 80I-A Assessment was completed. PCIT held that since business was commenced by assessee in assessment year 2004-05 having availed 100 per cent deduction from assessment year 2004-05 to assessment year 2008-09, assessee was entitled to claim deduction only to extent of 30 per cent from assessment year 2009-10 to assessment year 2013-14 and he denied deduction to assessee by invoking section 263. Tribunal set aside the Revision order. On appeal the Court held that no material was brought on record by revenue to show that merely by migration from IP-VPN to NLD-ILD license, a new and different undertaking of assessee within meaning of section 80IA(4)(ii) came into existence. Migration of licenses having occurred in December 2006 and Assessing Officer having allowed deductions for earlier years after making inquiries, assessee could not be deprived of similar deductions for subsequent period. (AY. 2010-11)