Allowing the appeal of the revenue the Tribunal held that ;’initial assessment year’ would be year in which substantial expansion is completed by assessee which would enable it to generate revenues and claim deduction thereon. Tribunal also held that , there is no time limit prescribed in S.80IE as to when substantial expansion should be completed by assessee .Accordingly the denial of exemption is held to be not justified . ( AY.2009-10)
Jay Shree Industries Ltd. v. JCIT (2018) 170 ITD 479 (Kol) (Trib.)
S. 80IE : Undertakings – North – Eastern States – ‘initial assessment year’ would be year in which substantial expansion is completed by assessee which would enable it to generate revenue- Denial of exemption is held to be not justified .