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2014 (11) TMI 353 - HC - Income TaxReopening of assessment u/s 147 – Notice issued beyond four years as provided u/s 148 – Permissibility od deduction u/s 80HHC and 80IB - Held that:- The Tribunal rightly found that on both counts the Revenue has failed to satisfy them that the assessment could have been reopened - notice u/s 148 of the Act is after 4 years from the end of relevant AY 2003-04 - The ground raised is that the deduction has been granted under both section 80HHC and 80IB and which is impermissible – the findings cannot be be treated as vitiated by perversity or any error of law apparent on the face of the record – as such no substantial question of law arises for consideration – Decided against revenue.
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