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2012 (9) TMI 148 - AT - Income TaxRe-invocation of Section 147 - AO had made assessment u/s 147 - Later on AO observed that he compute income by giving deduction under 80HHC but without deducting profit from undertaking claiming deduction u/s 80IA - AO again invoked the provision of u/s 147 and issue notice u/s 148 - Held that:- Assessee has disclosed all the material and relevant particulars, in respect of claim u/s 80IA and 80HHC of the Act - AO has invoked the provisions of Section 147 read with proviso thereunder on the basis of mere change in opinion and without bringing any tangible material for the formation of record. Therefore AO not complied with the statutory conditions contained in the provision of the section 147. Decision in favor of Assessee.
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