TMI Blog2019 (1) TMI 1698X X X X Extracts X X X X X X X X Extracts X X X X ..... perfectly correct in coming to the conclusion that the notice of reopening of assessment was invalid. From the reasons we gather that there was no element of lack of true and full disclosure on the part of the assessee, which resulted into any income chargeable to tax escaping assessment. The reasons clearly reveal that the AO was proceeding on the material which was already on record. In the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e, the Tribunal was correct in law in holding that the notice issued u/s 148 was not valid on ground that AO has not demonstrated the failure of the assessee in disclosing the material fact? 2. The appeal as arises out of the judgment of the Income Tax Appellate Tribunal in which it was held that the notice of reopening which was issued beyond the period of 4 years from the end of the re ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... istrative expenditure is not proportionate to the expenditure debited in consolidated P L A/c to the profit of 80-IA units, which has resulted in excess deduction u/s 80-IA. (iv) The assessee claimed deduction u/s 80-IA, 80HHB, 80HHBA, 80-HHC, 80HHE etc. However, exemption claimed u/s 80-IA was not reduced from other chapter VI-A deduction as per provisions contained in Section 80-IA. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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