The assessee had set up the undertaking for manufacture or production of an article or thing after 1st April, 2015 and the new asset was acquired and installed during the period beginning from 1st April, 2015 from which the date S. 32AD was introduced. The assessee claimed deduction u/s 32AD of the Act. The AO rejected the claim which was affirmed by the CIT(A). On appeal due to difference of opinion the point of reference is made to third member  to decide the issue whether the assesee is entitle to deduction u/s 32AD(1), in respect of investment made in the financial  year 2015-16. The  third member held that  the  assessee is entitled for allowance under S. 32AD.Neither the section 32AD nor Notification No. 61/2016/F.No. 142/13/2015, dt. 20th July, 2016 states that the deduction under S. 32AD is allowable only for the period starting from the date of notification. If the contention of the Revenue that the assessee is entitled to claim the benefit of S. 32AD only from the date of notification is accepted, then the condition of getting the benefit for a period five years from 1st April, 2016 is not fulfilled and this cannot be the mandate of the legislation. Once the notification was issued under S.  32AD specifying the area to be a backward area, it relates back to 1st April, 2015 onwards. Therefore, the provisions of S. 32AD are applicable for the investment made in financial year 2015-16 i.e., asst.AY. 2016-17.(AY. 20016-17)