TMI Blog2013 (10) TMI 148X X X X Extracts X X X X X X X X Extracts X X X X ..... iod of four years from the end of relevant assessment year only on the ground that explanation given below sub-section (13) of Section 80-IA of the Act substituted by the Finance (No. 2) Act, 2009 with retrospective effect i.e., from 1st April 2000 would not be admissible – Decided against the Revenue. - TAX APPEAL NO. 910 of 2012 - - - Dated:- 6-3-2013 - AKIL KURESHI AND SONIA GOKANI , JJ. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... March 2004. On scrutiny assessment under Section 143(3), the Assessing Officer had accepted the return and also the contentions of the assessee, exempting his income declared under Section 80IA to the tune of Rs. 6,12,357/=. Late on, in reopening proceedings initiated under Section 147 of the Act, notice was issued under Section 148 of the Act. The Assessing Officer disallowed deduction of Rs. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ent under Section 148 of the Income Tax Act beyond the period of four years from the end of relevant assessment year only on the ground that explanation given below sub-section (13) of Section 80-IA of the Act substituted by the Finance (No. 2) Act, 2009 with retrospective effect i.e., from 1st April 2000 would not be admissible. As both the CIT [A] and the Tribunal have rightly applied the law ..... X X X X Extracts X X X X X X X X Extracts X X X X
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