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TMI Blog2023 (3) TMI 51X X X X Extracts X X X X X X X X Extracts X X X X ..... D) and Container Freight Station (CFS) in the vicinity of Jawaharlal Nehru Port Trust (JNPT) - AO denied the benefit on the ground that the assessee had failed to furnish a certificate from the concerned Port Authority certifying that the structure was a part of the Port, which it considered mandatory in view of the Board s notification dated 23rd June 2000 followed by Circular No.10 of 2005 date ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Commissioner of Income Tax Vs. Continental Warehousing Corporation [ 2015 (5) TMI 656 - BOMBAY HIGH COURT ] Since a view has already been taken in Continental Warehousing Corporation (Supra) on the same issue and since there is no change in either the facts or the law, we are of the opinion that the questions proposed do not given rise to any substantial question of law. - INCOME TAX APPEAL ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ee was eligible for deduction claimed under section 80IA(4) of the Act, amounting to Rs.6,33,26,452/-? (ii) Whether on the facts and in the circumstances of the case and in law, the ITAT, Pune has not appreciated the facts findings made by the A.O. that Jawaharlal Nehru Port Trust (JNPT) has declined to issue a certificate that Warehousing of the assessee is part of the Port? (iii) Wheth ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... king which had set up an Inland Container Depot (ICD) and Container Freight Station (CFS) in the vicinity of Jawaharlal Nehru Port Trust (JNPT). In its return of income, the assessee claimed a deduction in terms of section 80IA(4) of the Act. (b) The Assessing Officer, however, denied the benefit on the ground that the assessee had failed to furnish a certificate from the concerned Port Autho ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e assessment year 2009-10, also came to be dismissed vide order dated 24th September 2019 following the views expressed by Delhi High Court in Container Corporation of India Ltd. Vs. Asstt. Commissioner of Income Tax (2012) 346 ITR 140 (Delhi) and this Court in Commissioner of Income Tax Vs. Continental Warehousing Corporation (2015) 374 ITR 645 (Bom). 6. Since a view has already been taken ..... X X X X Extracts X X X X X X X X Extracts X X X X
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