TMI Blog2019 (1) TMI 1214X X X X Extracts X X X X X X X X Extracts X X X X ..... ject to reassessment proceedings - Held that:- We are in agreement with the view taken by the Tribunal. The Tribunal has correctly placed reliance on a decision of the Supreme Court in the case of CIT Vs. Kelvinator of India Ltd [2010 (1) TMI 11 - SUPREME COURT OF INDIA] holding that even post amendment in Section 147 of the Act w.e.f. 1.4.1989, the concept of change of opinion would continue to a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Whether on the facts and circumstances of the case and in law, the Tribunal was correct in law in quashing the proceedings initiated by the Assessing Officer under Section 147 of the Income Tax Act, 1961? (ii) Whether on the facts and circumstances of the case and in law, the Tribunal was correct in law in holding that a decision of the Tribunal on the issue could not vest jurisdiction in th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessee had claimed deduction of profit derived from such export business in terms of Section 10B of the Income Tax Act, 1961 ( the Act for short). A part of such claim of ₹ 4.26 Crore (rounded off) related to the assessee's sale of goods to another EOU. Through the process of reassessment, the Assessing Officer desired to disallow such claim of the assessee. The Tribunal in the i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l deemed to be exports, payment for which is received either in Indian Rupees or in Foreign Exchange. The equivalent invoice value of foreign exchange in US-S 22,04,611.75/- has been realized within due dates, as per Bank Realization Certificates. As regards direct export the equivalent value is US-$ 89,422/- has been realized within due dates, as per Bank Realization Certificates. Copies of bills ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
