2014 (1) TMI 1082

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..... sessment year as reckoned from the end of the initial assessment year - While calculating the number of years initial assessment year should be excluded - Decided against Revenue. - Income Tax Reference No.116 of 1999 - - - Dated:- 10-12-2013 - MR. RAJIVE BHALLA AND DR. BHARAT BHUSHAN PARSOON, JJ. For the Appellant : Ms. Savita Saxena, Advocate For the Respondent : Mr. Akshay Bhan, Advo .....

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..... (hereinafter referred to as 'the Act'), clearly provides that benefit of deduction shall only be available for a period of seven years. In support of the said arguments, counsel for the revenue relies upon the first proviso to Section 80-J (3) of the Act. Counsel for the assessee submits that a perusal of the proviso clearly reveals that deficiency or any part thereof shall not be carried forwar .....

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..... tion applies, there shall, in accordance with and subject to the provisions of this section, be allowed, in computing the total income of the assessee, a deduction from such profits and gains (reduced by the deduction if any, admissible to the assessee under Section 80HH or section 80HHA) of so much of the amount thereof as does not exceed the amount calculated at the rate of six per cent, per ann .....

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