TMI Blog2023 (7) TMI 456X X X X Extracts X X X X X X X X Extracts X X X X ..... imed - HELD THAT:- As it is only industrial undertaking which is already claiming 100% deduction u/s 80IC as newly established unit cannot be allowed to claim 100% deduction u/s 80IC on substantial expansion undertaken by the same firm simultaneously. AO was apprised on behalf of the assessee that in the case of Hycron Electronics[ 2015 (6) TMI 725 - ITAT CHANDIGARH] has held the issue in favo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l purposes and direct the Ld. AO to consider the aforesaid judgments of Hon ble Supreme Court of India, and pass afresh order u/s 263 / 143(3) of the Act. - ITA No. 3486/Del/2017 - - - Dated:- 10-7-2023 - Sh. M. Balaganesh, Accountant Member And Sh.Anubhav Sharma, Judicial Member For the Assessee : None For the Revenue : Sh. Girish Kohli, Sr. DR ORDER PER ANUBHAV SHARMA, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that in consequence to the order of ld. PCIT the effect giving order u/s 263/143(3) of the Act has been passed. No further opportunity by way of notice is justified. 4. It comes up from the record that assessment order dated 27.02.2015 was made subject to the revision u/s 263 by Ld. PCIT as he had found the assessment order to be erroneous and prejudicial to the interest of the revenue for the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 80IC of the Act as newly established unit cannot be allowed to claim 100% deduction u/s 80IC on substantial expansion undertaken by the same firm simultaneously. The Ld. AO was apprised on behalf of the assessee that Hon ble Himachal Pradesh High Court in the case of Hycron Electronics ITA no. 20/105 dated 28.11.2017 has held the issue in favour of the assessee and the Chandigarh Tribunal judgment ..... X X X X Extracts X X X X X X X X Extracts X X X X
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