Commencement of business simply means taking first step in performing overall income producing activity

 Brief Facts of the case- The Revenue is aggrieved by the order of the Income Tax Appellate Tribunal (‘ITAT’). The assessee was incorporated in April, 2005 to carry on the business of out of home advertisement, consisting of street furniture, bill boards and transportation. It was awarded its first contract by New Delhi Municipal Corporation (NDMC) in March 2006 for construction of 197 Bus Queue Shelters (BQSs) on Build-Operate Transfer (BOT) basis. In terms of the contract, the assessee was required to undertake preliminary investigations, study, design, finance, construct, operate and ...