Per Shri V.S. Gaitonde, Accountant Member - These appeals have been filed by the assessee against the order of the Commissioner (Appeals), Belgarum. Shri Inamdar explained that although the assessee (if any) came into existence in 1965 through a statute, as the various points being canvassed now were not canvassed in the past, - the matters have to be examined now for the first time. For the year in question, the issues have been taken at the assessment and the appellate stage, for the assessment years 1974-75 to 1980-81.

2. As to facts, Shri Inamdar explained the background which impelled the Government of Goa to take steps for the rapid industrial development of the territory. Accordingly, it enacted a law named the Goa, Daman & Diu industrial Development Act, 1965 (GIDA) on 11-11-1965. The preamble stated :

"An Act to make special provision for securing the orderly establishment in industrial areas and industrial estates of industries in the Union territory of Goa, Daman & Diu and to assist generally in the organisation thereof, and for that purpose to establish an Industrial Development Corporation, and for purposes connected with the matters aforesaid."

The text of the said