IN THE HIGH COURT OF DELHI AT NEW DELHI
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ITA 51/2010 and ITA 79/2010
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THE COMMISSIONER OF INCOME TAX V ..... Appellant
Through : Mr Sanjeev Sabharwal
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versus
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EON TECHNOLOGY P LTD .....
Respondent
Through : Mr Prakash Kumar
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CORAM:
HON'BLE MR JUSTICE BADAR DURREZ AHMED
HON'BLE MR JUSTICE SIDDHARTH MRIDUL
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O R D E R
21.01.2010
CM 450/2010 in ITA 51/2010
Allowed subject to all just exceptions.
CM 451/2010 in ITA 51/2010 and CM 546/2009 in ITA 79/2010
The delay in re-filing is condoned.
These applications stand disposed of.
ITA 51/2010 and ITA 79/2010
These appeals pertain to the assessment years 2005-2006 and 2002-2003
arising out of the common order passed by the Income Tax Appellate Tribunal
dated 13.02.2009. The issue involved before the Tribunal was whether the
benefit under Section 10B could be claimed when the benefit under Section 80HHE
has already been received by the assessee in respect of the earlier year. The
Assessing Officer had made the addition on the basis of a negative answer to the
aforesaid question. The Commissioner of Income Tax (Appeals) as well as the
Income Tax Appellate Tribunal held in favour of the assessee. The Income Tax
Appellate Tribunal placed reliance on the decision of this Court in the case of
CIT v. Legato Systems India (P) Ltd: 203 CTR 101 (Delhi).
The learned counsel for the respondent/ assessee has also placed before
us an order passed in ITA 261/2009 entitled CIT v. E-Funds International Private
Limited decided on 19.08.2009 in which the identical issue was raised and the
appeal filed by the revenue was dismissed.
Following the decision of this Court in Legato Systems (supra) and the
order in ITA 261/2009, these appeals have also to be decided in favour of the
assessee and against the revenue.
These appeals are dismissed.
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BADAR DURREZ AHMED, J
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SIDDHARTH MRIDUL, J
JANUARY 21, 2010
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