CIT v Sauer Danfoss (P.) Ltd. [IT Appeal No. 1367 of 2010 dated 26.03.2012] (Delhi High Court) Facts of the case The assessee company was incorporated on 5.2.2001 under the Companies Act, 1956. Following is the sequence of events considered: Application for FIPB approval – 24.01.2001 First director appointed – 05.02.2001 Additional directors appointed – 10.02.2001 Physical possession of the leased premises – 15.02.2001 Opening of Bank account – 01.03.2001 Agreement for entering into lease of premises – 01.04.2001 Agreement for take over of running business of DHL – 21.05.2001 (to be effective from 01.06.2001)

Business is ready to commence upon set up of requisite infrastructure – Delhi HC