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TMI Blog2015 (7) TMI 1129X X X X Extracts X X X X X X X X Extracts X X X X ..... ment order? - Held that:- Rule 18C of the Rules itself provides that the same would apply only to undertaking established after April, 2006 and before March, 2011. In this case, admittedly, the Petitioner was established prior to April, 2006. Prima facie, it appears that 2008 Scheme would not have any application to the Petitioner. Further, the other issue namely income on renting of property shou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ) The Industrial Park does not qualify for deduction under Section 80IA of the Act as it is not notified under the Industrial Park Scheme 2008; (b) Rental Income is not eligible for deduction under Section 80IA of the Act as it is not income derived from operating the park; (c) 10% reduction in stock is claimed and it has to be examined; (d) Examination of Section 80IA (3) of the Act while a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ge of opinion and cannot justify reopening; (c) The Petitioner had made no claim for reduction in stock in its return of income for the Assessment Year 200910. Consequently, the aforesaid basis is factually incorrect; (d) As the exemption claimed under Section 80IA4(iii) of the Act, the application of Section 80IA(3) of the Act is specifically excluded. Thus, the exemption under Section 80IA4 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Rules while passing assessment order. However, this submissions ignores the fact that Rule 18C of the Rules itself provides that the same would apply only to undertaking established after April, 2006 and before March, 2011. In this case, admittedly, the Petitioner was established prior to April, 2006. Prima facie, it appears that 2008 Scheme would not have any application to the Petitioner. Furthe ..... X X X X Extracts X X X X X X X X Extracts X X X X
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