Samrat Plywood Ltd. v. ACIT (2021) 87 ITR 102 / 203 DTR 421 (Chd.)(Trib.)

S. 81C : Undertakings-Special category states-Initial assessment-Commencement Of Business On 28-12-2006-Loss can only be set off against profits of eligible unit in Assessment Year 2008-09. [S. 80IA(5), 80IC(7)]

Initial assessment year is previous year in which undertaking or enterprise begins to manufacture or produce articles or things. Commencement of  business on 28-12-2006. Tribunal also held that loss can only be set off against profits of  eligible unit in Assessment Year 2008-09. (AY.2008-09)