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2019 (12) TMI 434 - AT - Income TaxReopening of assessment u/s 147 - assessee has claimed deduction u/s 80IA of the Act in respect of Carbon Emission Reduction Certificates (CERs) sales which is not eligible for the deduction u/s 80IA - HELD THAT:- Income by way of transfer of carbon credit has been given a special treatment as chargeable to tax @ 10% and not as part of the normal business income of the assessee. The said amendment is prospective in nature and therefore, cannot be applied to the assessment years under consideration. In view of the above discussion as well as fact and circumstances of the case, we do not find any error or illegality in the impugned order of the ld. CIT(A) qua this issue. The only addition made by the AO in the reassessment proceedings has been deleted by the ld. CIT(A) which we have upheld in our findings on the merits of the issue in the Revenue-s appeals.
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