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2011 (3) TMI 889 - HC - Income TaxReassessment u/s 147 - Book profits u/s 115J - Since the issue on jurisdiction and limitation touch on the very reopening of the assessment, we feel, the proper course herein would be to set aside the order of the Tribunal, remand the matter back to the Tribunal with a direction to consider the issue of limitation and the jurisdiction under Section 147 to reopen the assessment - It is open to the parties herein to raise such contentions as are available to them, before the Tribunal - Decided in the favour of the assessee by way of remand
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