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 contrac

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