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).

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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