Allowing the appeal of the revenue the Court held that ; an assessee who avails of deduction for a period of 5 years @ 100% of profits and gains is entitled to deduction on ‘substantial expansion’ for remaining 5 Assessment Years @ 25% (or 30% where the assessee is a company) and not @ 100% (Mahabir Industries v. PCIT ( 2018) 406 ITR 315 (SC) distinguished).CA. No. 7208 of 2018, dt. 20.08.2018) ( AY.2011-12- 20112-2013)
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