Allowing the appeal of the assessee the Court held that, the initial year for the purpose of section 80-IA was the initial assessment year from which the deduction commenced and the assessee was entitled to the notional carry forward from that particular year. CBDT Circular No 1 of 2016 dt. 15-2-2016 (2016) 381 ITR 1 (St.) (AY. 2002-03, 2003-04)
South India Corporation Ltd. v. ACIT (2019) 412 ITR 239/ 177 DTR 337 (Ker.)(HC)
S. 80IA : Industrial undertakings-Assessee has option to choose initial year- Entitled to notional carry forward of loss from that particular Year. [S. 80]