PCIT v. T. M. International Logistic Ltd. (2022) 442 ITR 87 / 211 DTR 281 / 325 CTR 462 / 286 Taxman 101 (Cal.)(HC)

S. 80IA : Industrial undertakings-Infrastructure development-Operation and maintenance of Multi-Purpose berth in Port —Letter issued and agreement with Port authorities would satisfy requirement of law. [S. 119]

Dismissing the appeal the Court held that the letter from the port authorities and the agreement which were produced by the assessee were to be treated as a certificate issued by the port authorities and would satisfy the requirement in Circular No. 10 of 2005, dated December 16, 2005 ([2006] 280 ITR (St.) 1) issued by the Central Board of Direct Taxes. The Tribunal had rightly rejected the Department’s appeal and confirmed the order passed by the Commissioner (Appeals) allowing deduction under section 80IA to the assessee. (AY.2004-05, 2005-06)