Section 10A Deduction Allowed as New STP Unit Not Formed by Splitting Up: Bombay HC

PCIT Vs Mahindra Engineering Services Limited (Bombay High Court)

The Bombay High Court dismissed the appeal filed by the Revenue challenging the order of the Income Tax Appellate Tribunal (ITAT) which had allowed deduction under Section 10A of the Income-tax Act, 1961 to the assessee. The Revenue contended that the assessee’s Software Technology Park (STP) unit was formed by splitting up or reconstruction of an existing business and therefore did not satisfy the conditions prescribed under Section 10A(2).

The assessee had filed its return of income declaring nil income, w

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