The Tribunal held that the benefit of substantial expansion at 100 per cent. deduction would not be granted to existing units where the assessee had already availed of full deduction at 100 per cent. in the earlier five years and the benefit of deduction at 25 per cent. was available for the remaining period where the substantial expansion had taken place after January 7, 2003 and before April 1, 2012. High Court affirmed the order of the Tribunal On appeal the Court held that  assessee having set up a new industry of a kind mentioned in section 80-IC(2) and availing exemption of 100 per cent tax under section 80-IC(3) (which was admissible for five years) could claim exemption at same rate of 100 per cent beyond period of five years if it carried out substantial expansion in its manufacturing unit in terms of section 80-IC(8)(ix) within period of ten years.  Referred  PCIT v. Aarham Softronics [2019] 261 Taxman 529/412 ITR 623 (SC), (AY.2011-12)