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2010 (11) TMI 570 - AT - Income TaxAddition of income - Assessee disclosed fully and truly all material facts necessary for assessment - the first proviso to section 147 debarred the initiation of reassessment proceedings as the notice u/s 148 is issued on 18/23.07.2007 which is beyond the four years from the end of relevant assessment year which period ends on 31.03.2003 – It was held that assessment made thereon was bad in law Depreciation @ 60% on ITG networking equipments - it was the contention of Ld. AR that this issue is covered in favour of the assessee by the Special Bench decision in the case of DCIT v. Data Craft India Ltd - Such devices used as part of the computer in its functions and, thus, it can be termed as ‘computer’ only, therefore, eligible for depreciation @ 60% - In the result, the appeal filed by the Department as well as the CO filed by the assessee both are dismissed
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