SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Reopening of assessment u/s 147 was not valid as the Revenue Audit Report merely pointed out discrepancy in computation method and opined on applicability of Section 50C, which is an interpretation of law and not 'information' required for reopening. The Assessing Officer's reasons recorded for reopening showed lack of reason to believe income escaped assessment, being mere reason to suspect based on change of opinion. Section 50C was held inapplicable to sale after conversion of capital asset into stock-in-trade, following precedents. The appeal was allowed in favor of the assessee.
Reopening of assessment u/s 147 was not valid as the Revenue Audit Report merely pointed out discrepancy in computation method and opined on applicability of Section 50C, which is an interpretation of law and not 'information' required for reopening. The Assessing Officer's reasons recorded for reopening showed lack of reason to believe income escaped assessment, being mere reason to suspect based on change of opinion. Section 50C was held inapplicable to sale after conversion of capital asset into stock-in-trade, following precedents. The appeal was allowed in favor of the assessee.
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TaxTMI 
TaxTMI 
of 4891 
