2012 (9) TMI 516

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..... benefit of Section 80HH which view was squarely reversed in the case of Commissioner of Income-Tax vs. N.C. Budharaja and Co. and Another, reported in [1993 (9) TMI 6 - SUPREME COURT] thus any subsequent reversal of the legal position by the judgment of the Supreme Court does not authorise the Department to reopen the assessment, which stood closed on the basis of the law, as it stood at the relev .....

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..... rried out by the assessee would be entitled to the benefit of Section 80HH of the Act, which view was squarely reversed in the case of Commissioner of Income-Tax vs. N.C. Budharaja and Co. and Another, reported in [1993] 204 ITR 412. The subsequent reversal of the legal position by the judgment of the Supreme Court does not authorise the Department to reopen the assessment, which stood closed on t .....

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