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2011 (9) TMI 592 - HC - Income TaxValidity of Reassessment under 147 - Change of opinion - Held That:- When the assessment has been framed u/s 143(3) by considering the concerned matter and it was again made it clear during the course of proceedings initiated u/s 154, the initiation of proceedings u/s 148 on this issue is not only unjustified rather illegal and is against the natural law.
Deduction of Interest Income - Assessee Exporter - Bank Guarantee for executing order - Margin Money with Bank - Held That:- Deposits were exclusively for Business purpose thus entitled for deduction under 80HHC. Assessment under 147 - Disclosure of facts - When photocopies of banker‟s certificate confirming margin money has been kept shall be deemed that facts have been fully discussed during the course of Asstt. Proceedings now merely on the change of opinion as decided by Delhi High Court and Supreme Court given above an initiation of proceedings deserves to be withdrawn.
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