In Brief
Container Corporation of India Ltd. (CONCOR), a government company operating Inland Container Depots (ICDs) nationwide, claimed deductions under Section 80-IA of the Income Tax Act for assessment years 2003–2006. The revenue department rejected the claim, arguing ICDs do not qualify as 'Inland Ports' or 'infrastructure facilities'. The High Court allowed CONCOR's appeal. The Supreme Court upheld the High Court, holding that ICDs validly notified as infrastructure facilities by the CBDT in 1998 retain their eligibility even after a 2001 Finance Act amendment withdrew the Board's power to notify similar facilities. Once eligibility was established before the amendment, the 10-year exemption period cannot be curtailed. ICDs function as Inland Ports and therefore qualify for the deduction.
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