PCIT v. Verizon Communications India Pvt. Ltd. (2024)466 ITR 707 (Delhi)(HC)

S. 80IA : Industrial undertakings-Enterprises engaged in infrastructure development-Telecommunications Services-Expansion of business by acquiring international and national long distance licences-Entitled to deduction. [S.80IA(4)(ii)]

Held, dismissing the appeal, that no new undertaking had come into existence after March 31, 2005. The assessee had provided internet services from the assessment year 2002-03 and continued to provide internet services. The only difference was that it had expanded its business by adding to it a niche consumer base on acquisition of the international long distance and national long distance licences in the year 2008. The attempt of the Assessing Officer to excise a portion of the benefit, could not pass muster upon perusal of the plain language of section 80-IA(4)(ii). The Tribunal did not err in deleting the disallowance made under section 80-IA.No substantial question of law. (AY.2011-12)