Section 80JJAA Deduction Rejected as Amalgamation Amounted to Business Reorganisation

DCIT Vs Facets Gems Polishing Works Pvt. Ltd. (ITAT Surat) ITAT Denies Section 80IA Deduction Because Amalgamated Company Acquired Undertaking After 31 March 2007; ITAT Allows Revenue Appeal Because Amalgamation Barred Deductions Under Sections 80IA and 80JJAA; Windmill Tax Benefit Under Section 80IA Not Available Because Undertaking Was Transferred in Amalgamation; ITAT Holds Amalgamation Scheme Cannot Override Specific Restrictions Under Income Tax Act. The Income Tax Appellate Tribunal (ITAT), Surat Bench, considered the Revenue’s appeal against the order of the Commissioner of Income Ta...