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Reopening of assessment u/s 147 - eligibility of exemption u/s 11 - The ITAT Mumbai found that the reopening of the assessment was based on incorrect premises since the assessee had filed the return of income. Moreover, it held that the application of Section 12A(1)(ba) by the CIT(A) was inappropriate for the relevant assessment years as the amendment was prospective and not retrospective. Consequently, the ITAT quashed the assessment orders.
Reopening of assessment u/s 147 - eligibility of exemption u/s 11 - The ITAT Mumbai found that the reopening of the assessment was based on incorrect premises since the assessee had filed the return of income. Moreover, it held that the application of Section 12A(1)(ba) by the CIT(A) was inappropriate for the relevant assessment years as the amendment was prospective and not retrospective. Consequently, the ITAT quashed the assessment orders.
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