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2023 (6) TMI 30 - AT - Income TaxDeduction u/s 80IC - substantial expansion - period of deduction limited to 10 years - 9th year of claim of tax holiday - AO for disallowing the benefit of substantial expansion u/s 80IC(2) and confirming the deduction u/s 80IC only to the extent of 25% - HELD THAT:- Following the decision in case of Pr. CIT Vs. M/s Aarham Softronics [2019 (2) TMI 1285 - SUPREME COURT] and which has been followed in case of CIT Vs. Classic Binding Industries [2022 (6) TMI 1399 - ITAT CHANDIGARH], in the instant case, the assessee has started its business activity during financial year 2007-08 relevant to assessment year 2008-09 and has carried out substantial expansion in the financial year 2011-12 relevant to assessment year 2012-13 and the year under consideration being the 9th year of claim of tax holiday, it shall be eligible for claim of deduction @ 100% and not 25% of profits and gains from its business and matter is accordingly decided in favour of the assessee and the ground of appeal is allowed.
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