COMMISSIONER OF INCOME TAX CHENNAI III Vs. STATE INDUSTRIAL PROMOTION CORPORATION OF TAMIL NADU LIMITED

JUDGEMENT

(1.) COMMON Judgment : Tax Case Appeal Nos.112 to 114 of 2004 are filed by raising the following substantial questions of law:-

(2.) TAX Case Appeal No.205 of 2004 is filed by raising the following substantial questions of law:-

(3.) THE learned Senior Counsel appearing for the assessee in the first instance has contended that though for the earlier years as referred to above, the department itself has granted the benefit to the assessee under Section 10(20A) of the Income Tax Act, it has deviated from the earlier decision for the assessment year 1992-93 for no reason. However, the learned counsel for the department sought to sustain the order of the Tribunal by contending that the assessee would not claim rather cannot come within the ambit of Section 10(20A) of the Income Tax Act to claim the exemption. Thus she contends that the order of the Tribunal in T.C.No.205 of 2004 is correct and that of the decision in T.C.Nos.112 to 114 of 2004 is not correct.