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Reassessment of an infrastructure deduction claim under section 80-IA was considered invalid on three grounds. Eligibility could not be denied by treating an Indian-registered undertaking as foreign-owned merely because its shares were held by a foreign parent; the recorded reasons also failed to consider development of crane facilities and earlier treatment of the container-terminal business. Reopening after scrutiny on the basis of disclosed and previously examined material amounted to a change of opinion, absent new tangible material. Reassessment founded solely on a revenue audit objection was also treated as legally unsustainable. The reassessment notice, order rejecting objections, and consequential draft assessment proceedings were quashed.
Reassessment of an infrastructure deduction claim under section 80-IA was considered invalid on three grounds. Eligibility could not be denied by treating an Indian-registered undertaking as foreign-owned merely because its shares were held by a foreign parent; the recorded reasons also failed to consider development of crane facilities and earlier treatment of the container-terminal business. Reopening after scrutiny on the basis of disclosed and previously examined material amounted to a change of opinion, absent new tangible material. Reassessment founded solely on a revenue audit objection was also treated as legally unsustainable. The reassessment notice, order rejecting objections, and consequential draft assessment proceedings were quashed.
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