In the result, appeals filed by the Assessee are hereby allowed
disallowance u/s. 35E only on the ground that the assessee does not meet the parameters of eligibility prescribed within section 35E of the Act and the assessee also failed to commence the commercial production during the assessment year 2003-04. I.T.A Nos. 1860 to 1863/Ahd/2019 A.Y. 2003-04 to 2006-07 Page No 9 Gujarat Power Corporation Ltd. vs. ACIT