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2023 (7) TMI 698

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..... n of Classic Binding Industries [ 2018 (8) TMI 1209 - SUPREME COURT] - 100% or 25% - whether Assessees were entitled to 100% exemption and this Court in the case of Aarham Softronics [ 2019 (2) TMI 1285 - SUPREME COURT] has held that the judgment in Classic Binding Industries case had omitted to take note of the definition of Initial Assessment Year contained in Section 80-IC and had instea .....

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..... deduction has attained finality. In so far as the case of M/s. Friends Alloys is concerned, the Revenue has conceded to the fact that the said Assessee is entitled to exemption. - HON'BLE MRS. JUSTICE B.V. NAGARATHNA And HON'BLE MR. JUSTICE PRASHANT KUMAR MISHRA For the Petitioner : Mr. Abhinav Jain, Adv. Mr. Rajeev Singh, AOR Mr. Tarun Gupta, AOR Mr. Anmol Mishra, Adv. Mr. Abhis .....

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..... ed counsel for the appellant(s) submitted that essentially the controversy was, as to, whether, the Assessees were entitled to 100% exemption and this Court in the case of Principal Commissioner of Income Tax, Shimla V/s Aarham Softronics (2020) 11 SCC 551 has held that the judgment in Classic Binding Industries case had omitted to take note of the definition of Initial Assessment Year contained .....

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..... to the case at hand and therefore, the High Court, which has stated that the substantial questions of law were answered against the Assessees and in favour of the Revenue on the basis of Classic Binding Industries case, will have to be now set aside. Consequently, the Assessees succeed and are entitled to 100% exemption. In this regard, it is relevant to notice that in the case of Tejpal Chaud .....

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