S. 80IA Initial assessment year means 1st year opted by assessee for deduction

Brief: The assessee being eligible had option to start claiming deduction from any of the assessment years within time frame of Ay 2004-2005 to AY 2019-2020. Assessee exercises the option in AY 2008-09. AO made the disallowance by holding that assessment year 2004-05 is the initial AY. ITAT issued order in favour of Assessee. Fact of the Case: Briefly, the facts of the case are that the assessee established two wind mills in District Jaisalmer, Rajasthan a 20 Mega Watt (MW) at village Gorera and 25 MW at village Soda Mada on 30.3.2004 and 24.1.2004 respectively. The assessee claimed deduction ...