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2019 (8) TMI 982 - AT - Income TaxDeduction u/s 80IC - definition of the initial assessment year contained in clause (v) of sub-section(8) of section 80IC can lead to a situation where there can be more than one assessment year within the said period of ten years - HELD THAT:- It is now settled law that even a new undertaking, which has claimed deduction of its eligible profits @ 100% thereof for the first five years, is entitled to claim deduction @ 100% of its profits thereafter on account of substantial expansion undertaken by it. Since in the present case, the fact that the assessee had undertaken substantial expansion in A.Y. 2010-11 is not disputed, the assessee, we hold, is entitled to claim deduction @ 100% of its eligible profits even if it has already claimed deduction of its profits at the said rate for five years, in view of the law laid down by the apex court in this regard in its decision in the case of M/s Aarham Softronics [2019 (2) TMI 1285 - SUPREME COURT]. Uphold the order of the Ld.CIT(A) on merits. All the appeals of the Revenue,challenging the order of the Ld.CIT(A) on merits are therefore dismissed. Now taking up the assessee’s appeals against the action of the CIT(A) in not disposing off the legal ground raised by it, challenging the validity of assessment framed under section 147 of the Act, the Ld. Counsel for the assessee stated that it do not wish to press the grounds raised.
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