Assessee set-up a manufacturing unit in Himachal Pradesh on 1-4-2007 and started claiming 100 per cent deduction under section 80IC of the Act. In thee Assessment year 2012-13  the  assessee undertook substantial expansion. The Assessing Officer disallowed claim of assessee of 100 per cent deduction and allowed deduction to extent of 25 per-cent. On appeal the Tribunal held that  an assessee who sets up a new unit as mentioned under section 80-IC(2)(ii) would be eligible for 100 per-cent deduction for 5 years commencing from initial assessment year and for next five years deduction would be 25 per cent. Since assessee had carried out substantial expansion as defined under section 80IC(8)(ix) within aforesaid period of 10 years, said previous year in which substantial expansion was undertaken would become ‘initial assessment year’ and assessee would be entitled to 100 per cent deduction for a total period of ten years as provided in section 80IC(6)  of the Act. (AY. 2015-16)