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ITAT held the reassessment invalid and set aside the reopening. The Tribunal found the AO had examined and allowed the assessee's deduction under s.80IA during original assessment on receipt of Form 10CCB and project accounts, and the reassessment was prompted solely by a change of opinion without fresh tangible material. The Revenue's alternative grounds - reduction of s.80IA profits in computing other Chapter VIA deductions, concurrent claims under s.80HHC and s.80HHE, and disallowance of prior period expenses - were rejected as contrary to binding principles and on facts. The reassessment order was quashed and the assessee's assessments restored.
ITAT held the reassessment invalid and set aside the reopening. The Tribunal found the AO had examined and allowed the assessee's deduction under s.80IA during original assessment on receipt of Form 10CCB and project accounts, and the reassessment was prompted solely by a change of opinion without fresh tangible material. The Revenue's alternative grounds - reduction of s.80IA profits in computing other Chapter VIA deductions, concurrent claims under s.80HHC and s.80HHE, and disallowance of prior period expenses - were rejected as contrary to binding principles and on facts. The reassessment order was quashed and the assessee's assessments restored.
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