other section contained in Chapter VI-A or in section 10-A or section 10-AA or section 10-B or section ... under this section, where the total period of deduction inclusive of the period of deduction under this section, or under section 80-IC or under
substantial
expansions. The purport behind the three types of deductions
specified in Section 80-IA , Section 80-IB and Section 80-IC is,
thus, different ... Section 80-IA and Section 80-IB , for
the purpose of counting ten years, is provided in sub-section (6)
of Section 80-IC
different from the
definition contained in Section 80-IB. Further, Sub-section (3) of Section
80-IC mentions about the deduction that is permissible, namely ... section (4) of Section 80-IB as well. It would mean that total
deduction under Section 80-IB as well as 80-IC
legislative history and purpose behind the insertion of
Section 80-IA , 80-IB and 80-IC has already been mentioned
above. We have to keep ... doing
violence to the provisions of sub-section (3) read with sub-section
(6) of Section 80-IC. A pragmatic and reasonable interpretation of
Section
levy of penalty u/s 271(1)(c) on the enhanced claim of deduction
u/s 80IC on carrying out substantial expansion has been considered ... interpretation of provisions of Section 80IC of the Act for claim of
deduction under section 80IC @ 100% on undertaking substantial expansion in the
assessment year
specific restriction in the Section. There is no
suggestion in the language of the section that incentive u/s 80
IC is not available ... expansion and claimed deduction u/s 80 IB(iv). The AO rejected the
same and observed that benefit could be availed u/s 80 IC
Section 80-IC.
(c) Substantial expansion cannot be confined to one expansion.
As long as requirement of Section 80-IC(8)(ix) is met, there ... doing
violence to the provisions of sub-section (3) read with sub-
section (6) of Section 80-IC. A pragmatic and reasonable
interpretation of Section
above the Addl. CIT/DRP erred in computing deduction under
section 80 'IC by applying the proportion of turnover of the eligible unit ... submitted by the Appellant and should have allowed deduction under section 80 'IC
accordingly.
The claim of the Appellant be accepted in toto
Explanation (b) of Section 80-IB
22.
(11C) and Section 80-IB(14)(c) would reflect that, earlier [till
Section 80-IC was inserted ... deduction under
Section 80-IA , 80-IB or 80-IC substantially expands in the
year 2003 and claims deduction under Section 80-IC first
time
decide the said question.
7. Section 80 IC of the Act reads as under:-
"80-IC. Special provisions in respect of
certain undertakings ... section, or under the second proviso to
sub-section (4) of section 80-IB or under
section 10C, as the case may be, exceeds
