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    <title>2007 (1) TMI 279 - ITAT DELHI</title>
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    <description>The Tribunal upheld the validity of the reopening of assessment under section 147, adding Rs. 10.80 crores to the assessee&#039;s income as &quot;Income from Other Sources.&quot; It clarified that if shares were acquired in exchange for shares held in another entity, section 2(24)(iv) would not apply. The Tribunal also confirmed the legality of the merger between EHIRC, Delhi, and EHIRC, Chandigarh, rejecting claims of converting a charitable society into a profit-making entity. The value of shares was to be re-evaluated, and interest under section 234B was upheld as mandatory. Penalty proceedings under section 271(1)(c) were not appealable. The Assessing Officer was directed to reassess the case.</description>
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    <pubDate>Thu, 25 Jan 2007 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=119641</link>
      <description>The Tribunal upheld the validity of the reopening of assessment under section 147, adding Rs. 10.80 crores to the assessee&#039;s income as &quot;Income from Other Sources.&quot; It clarified that if shares were acquired in exchange for shares held in another entity, section 2(24)(iv) would not apply. The Tribunal also confirmed the legality of the merger between EHIRC, Delhi, and EHIRC, Chandigarh, rejecting claims of converting a charitable society into a profit-making entity. The value of shares was to be re-evaluated, and interest under section 234B was upheld as mandatory. Penalty proceedings under section 271(1)(c) were not appealable. The Assessing Officer was directed to reassess the case.</description>
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      <pubDate>Thu, 25 Jan 2007 00:00:00 +0530</pubDate>
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