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TMI Blog2019 (7) TMI 879X X X X Extracts X X X X X X X X Extracts X X X X ..... ned in clause (ix) of sub-section (8) of Section 80-IC by such an undertaking or enterprise, within the aforesaid period of 10 years, the said previous year in which the substantial expansion is undertaken would become initial assessment year , and from that assessment year the assessee shall be entitled to 100% deductions of the profits and gains. Such deduction, however, would be for a total ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... llant : Mr. Vivek Sethi, Senior Panel Counsel ORDER AJAY TEWARI, J. (Oral) 1. This appeal has been filed by the Revenue under Section 260A of the Income Tax Act, 1961 (in short the Act ) against the order of the Income Tax Appellate Tribunal, Chandigarh in ITA No.378/Chd/2017 dated 12.02.2018 for the assessment year 2012-2013. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessment year in the two sections, viz. Sections 80-IB and 80-IC are materially different. The definition of initial assessment year under Section 80-IC has made all the difference. Therefore, we are of the opinion that the aforesaid judgment does not lay down the correct law. ( b) An undertaking or an enterprise which had set up a new unit between 7th January, 20 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... entitled to 100% deductions of the profits and gains. ( d) Such deduction, however, would be for a total period of 10 years, as provided in sub-section (6). For example, if the expansion is carried out immediately, on the completion of first five years, the assessee would be entitled to 100% deduction again for the next five years. On the other hand, if substantial exp ..... X X X X Extracts X X X X X X X X Extracts X X X X
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