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2019 (5) TMI 309 - HC - Income TaxDeduction u/s 80IC - substantial expansion - initial assessment year' for availing the deduction - exemption at the same rate of 100% beyond the period of five years on the grounds that the assessee has now carried out substantial expansion in its manufacture unit - HELD THAT:- Issue involved herein is covered by the decision of M/S. AARHAM SOFTRONICS [2019 (2) TMI 1285 - SUPREME COURT] as held deduction, would be for a total period of 10 years, as provided in sub-section (6). 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 expansion is undertaken, say, in 8th year by an assessee such an assessee would be entitled to 100% deduction for the first five years, deduction @ 25% of the profits and gains for the next two years and @ 100% again from 8th year as this year becomes ‘initial assessment year’ once again. However, this 100% deduction would be for remaining three years, i.e., 8th, 9th and 10th assessment years. - Decided in favour of assessee.
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