2. Assessee carrying on the business of development and export of information technology related software solutions, had during the relevant previous year claimed exemption of Rs. 65,75,677 under section 10A of the Act. Assessment was completed under section 143(3) and the Assessing Officer allowed the claim. However, CIT for a reasoning that the Assessing Officer had not examined the assessee’s claim of deduction under section 10A of the Act properly, issued notice under section 10A of the Act. According to the CIT, there was a change in ownership or the beneficial interest in the assessee-company during the relevant previous year thereby depriving it the benefit of deduction under section 10A of the Act. In reply to the notice, assessee contended that there was no change in the ownership nor beneficial interest. In support of this, the following shareholding pattern was submitted by the assessee :

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