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    <title>1992 (4) TMI 80 - ITAT DELHI-C</title>
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    <description>The ITAT cancelled reassessment orders for excess deduction under section 80HH due to inclusion of interest income, citing inadequate initiation based on disclosure of primary facts. It found the assessee had adequately disclosed interest income in previous years, leading to the conclusion of valid reassessment. The principle of res judicata was considered, emphasizing the need for fresh material to support a departure from previous decisions. The ITAT highlighted the invalidity of reassessment based on incomplete particulars and change of opinion without new evidence. The adjustment of interest paid against interest income was not extensively addressed in the final decision, with the appeals being allowed based on disclosure and lack of fresh material.</description>
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    <pubDate>Fri, 03 Apr 1992 00:00:00 +0530</pubDate>
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      <title>1992 (4) TMI 80 - ITAT DELHI-C</title>
      <link>https://www.taxtmi.com/caselaws?id=63964</link>
      <description>The ITAT cancelled reassessment orders for excess deduction under section 80HH due to inclusion of interest income, citing inadequate initiation based on disclosure of primary facts. It found the assessee had adequately disclosed interest income in previous years, leading to the conclusion of valid reassessment. The principle of res judicata was considered, emphasizing the need for fresh material to support a departure from previous decisions. The ITAT highlighted the invalidity of reassessment based on incomplete particulars and change of opinion without new evidence. The adjustment of interest paid against interest income was not extensively addressed in the final decision, with the appeals being allowed based on disclosure and lack of fresh material.</description>
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      <pubDate>Fri, 03 Apr 1992 00:00:00 +0530</pubDate>
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