Assessment amendment powers allow exclusion of capital gains after prescribed reinvestment and permit post receipt foreign exchange deductions. The amendment empowers Assessing Officers to amend assessments where a taxed capital gain is subsequently relieved because the taxpayer acquires the qualifying new asset or deposits/invests the gain within the extended reinvestment period, and where deduction for royalty/commission/fees previously denied for not having been received or brought into convertible foreign exchange is later available because such receipts are brought into India; rectification procedure applies and a four year limitation is reckoned from the end of the previous year in which the compensatory or relevant income was received, with a specified exclusion in computing that period.
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Provisions expressly mentioned in the judgment/order text.
Assessment amendment powers allow exclusion of capital gains after prescribed reinvestment and permit post receipt foreign exchange deductions.
The amendment empowers Assessing Officers to amend assessments where a taxed capital gain is subsequently relieved because the taxpayer acquires the qualifying new asset or deposits/invests the gain within the extended reinvestment period, and where deduction for royalty/commission/fees previously denied for not having been received or brought into convertible foreign exchange is later available because such receipts are brought into India; rectification procedure applies and a four year limitation is reckoned from the end of the previous year in which the compensatory or relevant income was received, with a specified exclusion in computing that period.
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