TaxTMI 
TaxTMI 
2021 (12) TMI 454
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....NTANT MEMBER: This appeal by the assessee is preferred against the order of the Commissioner of Income Tax [Appeals] - 20, New Delhi dated 30.08.2018 pertaining to Assessment Year 2015-16. 2. The sum and substance of the grievance of the assessee is that the ld. CIT(A) erred in confirming the order of the AO who allowed the claim of deduction u/s 80IC of the Income-tax Act, 1961 [hereinafter ref....
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....ricted the claim of deduction to 25%. 5. The assessee carried the matter before the ld. CIT(A) but without any success. 6. Before us, the ld counsel for the assessee vehemently stated that it has carried out substantial expansion in the existing manufacturing unit at Baddi in Assessment Year 2012-13 and, therefore, the assessee is eligible for claim of deduction @ 100%. It is the say of the ld. ....
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.... August, 2018 in Classic Binding Industries case omitted to take note of the definition 'initial assessment year' contained in Section 80-IC itself and instead based its conclusion on the definition contained in Section 80-IB, which does not apply in these cases. The definitions of 'initial assessment year' in the two sections, viz. Sections 80-IB and 80-IC are materially different....
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....on (8) of Section 80-IC by such an undertaking or enterprise, within the aforesaid period of 10 years, the said previous year in which the substantial expansion is undertaken would become 'initial assessment year', and from that assessment year the assessee shall been entitled to 100% deductions of the profits and gains. (d) Such deduction, however, would be for a total period of 10 year....