Reopening assessments beyond four years requires nondisclosure of material facts; mere change of opinion or general allegations invalidates reassessme...
Deduction under section 80IA concerned the allowability and apportionment of common salary expenses between a power generation unit and a share trading business. The tribunal accepted the salary claimed as debited to profit and loss but held that the allocation between the two businesses should be made by reference to their respective turnover, not a fixed 50:50 split; it set aside the AO's allocation and directed recomputation of the 80IA deduction by apportioning salary in the ratio of turnover. Grounds raised by the assessee were partly allowed.
Deduction under section 80IA concerned the allowability and apportionment of common salary expenses between a power generation unit and a share trading business. The tribunal accepted the salary claimed as debited to profit and loss but held that the allocation between the two businesses should be made by reference to their respective turnover, not a fixed 50:50 split; it set aside the AO's allocation and directed recomputation of the 80IA deduction by apportioning salary in the ratio of turnover. Grounds raised by the assessee were partly allowed.
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