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2019 (10) TMI 859 - AT - Income TaxDeduction u/s 80IC - whether the assessee is entitled for deduction u/s 80IC @ 100% for 6th to 10th assessment years from the year of the manufacturing as claimed by the assessee, on the ground that for the purpose of substantial expansion “initial assessment years” would be separate? - HELD THAT:- We find that Hon’ble Supreme Court in the case of Aarham Softronics [2019 (2) TMI 1285 - SUPREME COURT] has held in case of substantial expansion, the said previous year would become initial assessment year and from that assessment year the assessee shall be entitled to hundred percent deduction of the profit and gains - CIT(A) on the issue in dispute is set aside and the Assessing Officer is directed to allow the deduction under section 80IC of the Act to the assessee’s. Disallowance u/s 14A - assessee has challenged the disallowance only on the ground that statutory precondition of invoking Rule 8D has not been satisfied by the AO - HELD THAT:- We find that the Assessing Officer has properly recorded the dissatisfaction on the claim of assessee of expenses of ₹ 2000 per month incurred for earning dividend income No error in the order of the learned CIT(A) in upholding the disallowance under section 14A of the Act read with Rule 8D of the Income Tax Rules. The ground of the appeal of the assessee is accordingly dismissed.
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