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| The Tax Publishers2020 TaxPub(DT) 3882 (Mum-Trib) INCOME TAX ACT, 1961
Section 80-IA(4)
CFS was an inland port as it carried out functions of warehousing, customs clearance and transport of goods from its location to sea-port and vice versa by rail or by trucks in containers and, therefore, its income was eligible to deduction under section 80-IA(4).
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Deduction under section 80-IA(4) - Allowability - Container freight station (CFS) -
Assessee claimed deduction under section 80-IA(4). AO disallowed deduction for the reason, that assessee's Container Freight Stations (CFS) was neither a port nor an Inland Port, and thus, not an eligible infrastructural facility as provided in the 'Explanation to section 80-IA(4). Held: CFS was an inland port as it carried out functions of warehousing, customs clearance and transport of goods from its location to sea-port and vice-versa by rail or by trucks in containers and, therefore, its income was eligible to deduction under section 80-IA(4).
Relied:CIT v. Container Corporation of India Ltd. (2018) 404 ITR 397 (SC) : 2018 TaxPub(DT) 2137 (SC).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2015-16
INCOME TAX ACT, 1961
Section 14A Section 115JB
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