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2012 (1) TMI 377

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..... N. Vijayakumaran, Both these appeals for assessment years 2006-07 2007-08 are by the department against the orders of Ld. C.I.T.(A)-XII, Kolkata dated 29/12/2010. 2. The first ground is on allowing of deductions of ₹ 1,52,77,467/- and ₹ 2,48,98,146/- by the ld. C.I.T.(A), which were disallowed by the ld. A.O. u/s. 80-IA of the Act for assessment year .....

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..... see, viz., Vantage Advertising Pvt. Ltd. in ITA Nos. 1054 1055/Kol/2008 held that the bus shelters, toilet blocks etc. were functionally necessary and part parcel of highway infrastructure. Therefore, respectfully following the above decisions of the Tribunal, we confirm the orders of ld. C.I.T.(A) for the assessment years under appeal also, who followed the decision of I.T.A.T. referred supr .....

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..... rial to the satisfaction of the ld. A.O. Hence the second issue for assessment year 2006-07 is to be treated as alloweod for statistical purposes. 5. In the result, the revenue s appeal for assessment year 2006-07 is treated as partly allowed for statistical purposes and that for assessment year 2007-08 is dismissed. Order pronounced in the open Court on 09/1/2012 - .....

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