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Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
Section 260-A permits a High Court appeal only where a substantial question of law arises; it does not allow reappreciation of evidence or replacement of concurrent factual findings. Concurrent findings that road and infrastructure works qualified the assessee as a developer eligible for deduction under section 80-IA(4) were based on the record, with no perversity or erroneous legal test shown. Reliance on a previously confirmed Tribunal order and dismissal of a similar appeal for another assessment year did not create a substantial question of law. The Department's appeal was dismissed.
Section 260-A permits a High Court appeal only where a substantial question of law arises; it does not allow reappreciation of evidence or replacement of concurrent factual findings. Concurrent findings that road and infrastructure works qualified the assessee as a developer eligible for deduction under section 80-IA(4) were based on the record, with no perversity or erroneous legal test shown. Reliance on a previously confirmed Tribunal order and dismissal of a similar appeal for another assessment year did not create a substantial question of law. The Department's appeal was dismissed.
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