https://www.taxtmi.com/caselaws?id=345710 For deduction under Section 80-IA, SSI eligibility was held to be tested only with reference to the initial assessment year, not re-examined in each of the ten successive years. The Court reasoned that the statutory scheme links the condition to the previous year relevant to the initial assessment year, and a contrary view would defeat the incentive provision. It also held that revision under Section 263 was unavailable because the Assessing Officer had adopted a plausible view on a debatable issue, so the order was not both erroneous and prejudicial to the Revenue. Reopening under Section 147, which depended only on the unsustainable revision order, was therefore invalid. en-us Thu, 20 Jul 2017 00:00:00 +0530 Mon, 13 Nov 2017 18:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=345710 For deduction under Section 80-IA, SSI eligibility was held to be tested only with reference to the initial assessment year, not re-examined in each of the ten successive years. The Court reasoned that the statutory scheme links the condition to the previous year relevant to the initial assessment year, and a contrary view would defeat the incentive provision. It also held that revision under Section 263 was unavailable because the Assessing Officer had adopted a plausible view on a debatable issue, so the order was not both erroneous and prejudicial to the Revenue. Reopening under Section 147, which depended only on the unsustainable revision order, was therefore invalid. Case-Laws Income Tax Thu, 20 Jul 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=345710