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Documents citing Dcit Cen Cir 4(2) Cen Rg 4, Mumbai vs Ushdev International Ltd, Mumbai on 27 December, 2021

Malpani Sales Corporation,, Pune vs Assessee

14. From the above provisions of sub-s.(2) of s.80IA of the act, it is evident that the assessee is granted the option to select 'initial assessment year' i.e. first assessment year of the 'any ten consecutive assessment years out of fifteen years. Starting assessment year for counting the duration of fifteen years is also provided in the aid sub-section. As per thee provisions, the assessee is not allowed to jump the assessment year once an initial assessment year is opted. Therefore, we find no fault with the assessee in selecting the asst.year 2004-05 as the 'initial assessment year'. In this regard, i.e. on the issue of assessee's option to select the 'initial assessment year', we have perused the citations relied upon by the assessee's counsel. The conclusion by the Tribunal Mumbai bench decision in ITA No.4620/Mum/2007 (asst.yr.2004-05) in the case of DCIT v. Ushdev International Ltd. Is straight on this issue of initial assessment year and the option to the assessee and the held portion of the decision reads as under:
Income Tax Appellate Tribunal - Pune Cites 1 - Cited by 0 - Full Document
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