JUDGMENT judgment of court was delivered by N. Kumar J.-As common question of law is involved in all these three appeals and assessee is also same and orders pertain to different assessment years, they are taken up for consideration together and disposed of by this common order. substantial question of law raised in these appeals is as under: "Whether, on facts and in circumstances of case, Tribunal was justified in law in holding that STPI unit established by assessee for which section 10A deduction is claimed was not formed by splitting up or reconstruction or transfer of used assets of existing unit and, consequently, without appreciating fact that as per section 10A assessee is not eligible for section 10A deduction if STPI unit is not new undertaking but formed by splitting up of existing unit and reconstruction of business already in existence?" assessee is Indian company engaged in business of computer software development and business processing out source. During financial year 2005-06, assessee was running its business from nonSTPI unit under rented premises. In this period party has applied for permission to set up STPI unit at ground floor of said premises. STPI authorities granted approval for setting up of STPI unit for development of computer service/IT enabled services (ITES) on February 31, 2006. assessee started business in newly set up unit during financial year 2006-07. assessee also continued to carry out its business from non-STPI unit also. Separate books of account were maintained by assessee for STPI unit and non-STPI unit. In respect of STPI unit claim for deduction under section 10A made by assessee was rejected on ground that STPI unit is found by splitting of existing unit. In appeal, on appreciation of material on record, said order was set aside and benefit under section 10A was extended to STPI unit and Revenue preferred appeal before Tribunal which has confirmed same. This court had occasion to consider similar question in case of CIT v. Wipro GE Medical System Ltd. reported in [2015] 4 ITR-OL 288 (Karn); [2014] 226 Taxman 156 (Karn), and in case of CIT v. Maxim India Integrated Circuit Design (P.) Ltd. reported in [2011] 202 Taxman 365 (Karn) and CIT v. Expert Outsource (P.) Ltd. reported in [2013] 358 ITR 518 (Karn). law laid down in aforesaid cases squarely applies to facts of this case. Therefore, findings recorded by both appellate authorities are in accordance with law. Thus, substantial question of law raised in these appeals is answered in favour of assessee and against Revenue and appeals are dismissed. *** Commissioner of Income-tax v. Quest Informatics Pvt. Ltd