TMI Blog2014 (5) TMI 667X X X X Extracts X X X X X X X X Extracts X X X X ..... new fact/material or information which came to the knowledge of the AO on the basis of which the assessment was re-opened - the CIT(A) has given a finding of fact based on cogent appreciation of the material on the record that the plot of land on which the Housing Project is undertaken if more than one acre in area - the Assessee is eligible to claim the deductions u/s 80IB(10) of the Act – the o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g that re-opening of the assessment is bad in law, under the facts and circumstances of the case ? B. The Hon'ble ITAT erred in holding that the Assessing Officer issued notice u/s. 148 only due to change of opinion, which is actually not correct as the AO has not discussed at all in the original Assessment order regarding deduction u/s 80IB(10) and therefore it cannot be said that there is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... erial or information which came to the knowledge of the Assessing Officer on the basis of which the assessment was re-opened. Furthermore, the Commissioner of Income Tax (Appeals) has given a finding of fact based on cogent appreciation of the material on the record that the plot of land on which the Housing Project is undertaken if more than one acre in area and, therefore, the Assessee is eligib ..... X X X X Extracts X X X X X X X X Extracts X X X X
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