Meaning of “Initial assessment year”

Case Name : Indian Rayon Corpn. Ltd. Vs. CIT

Citation :[1998] 97 TAXMAN 501/231 ITR 26 (BOM.)

Court : Bombay High Court

Section : 80J

Meaning : The expression ‘initial assessment year’ has been defined in sub-section (2) of section 80j to mean ‘the assessment year relevant to the previous year in which the industrial undertaking begins to manufacture or produce articles’. Sub-section (2) clearly provides that such assessment year thereafter in that section [which obviously includes sub-section (3) thereof] shall be referred to as the ‘initial assessment year’. On the face of such clear and unambiguous language of sub-section (2), there is no scope for any doubt about the true meaning of the expression ‘initial assessment year’ appearing in clause (i) of the proviso to sub-section (3) of section 80j.

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