https://www.taxtmi.com/caselaws?id=76763 HC set aside notice u/s 148 and held reopening unjustified. AO's view that Rule 8 prevents setting off 40% plantation losses against normal business profits was incorrect; assessee entitled to adjust such losses. Computational errors in the assessment should be corrected by rectification u/s 154, not reopening u/s 147. Investment under s.54EC was timely based on payment date to the bank (within six months), so exemption was properly claimed. All four units qualified under s.10B; profits of three units were deductible and the loss of the fourth could be set off against normal business income, defeating the stated grounds for reopening. en-us Thu, 01 Apr 2010 00:00:00 +0530 Sat, 30 Aug 2025 12:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=76763 HC set aside notice u/s 148 and held reopening unjustified. AO's view that Rule 8 prevents setting off 40% plantation losses against normal business profits was incorrect; assessee entitled to adjust such losses. Computational errors in the assessment should be corrected by rectification u/s 154, not reopening u/s 147. Investment under s.54EC was timely based on payment date to the bank (within six months), so exemption was properly claimed. All four units qualified under s.10B; profits of three units were deductible and the loss of the fourth could be set off against normal business income, defeating the stated grounds for reopening. Case-Laws Income Tax Thu, 01 Apr 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=76763