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2012 (4) TMI 342 - HC - Income TaxJurisdiction of AO u/s 147 - Deductions u/s 80-1A - held that:- The assessee’s own case was comparable as an indicator/factor which should have been taken into consideration and not that of any other assessee for a different period which could not be the foundation or the reason to reopen assessment. - when this high rate of profit is accepted in subsequent assessment years, mere high profit without anything more could not be the ground for reopening assessment. Regarding reopening of assessment on the ground of excess payment of wages - held that:- where the Assessing Officer holds that expenditure on wages of Rs.2,58,040/- was not sufficient to defray the wages of ten or more workers, the observation of the Assessing Officer was wrong. - we cannot accept that the Assessing Officer was right in reopening assessment. - Decided in favor of assessee.
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