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    <description>Reopening under sections 147 and 148 is stated to rest on a prima facie belief of escapement of income, and a mere change of opinion does not bar initiation where material supports that belief. For partners&#039; remuneration under section 40(b), book profit is the net profit shown in the profit and loss account, subject only to statutory adjustments, so interest on fixed deposits kept for business facilities was included in book profit. Ad hoc disallowances were then dealt with separately: travelling expense disallowance and accrued interest addition were deleted, business promotion disallowance was partly sustained, and staff welfare and entertainment disallowance was sustained.</description>
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      <description>Reopening under sections 147 and 148 is stated to rest on a prima facie belief of escapement of income, and a mere change of opinion does not bar initiation where material supports that belief. For partners&#039; remuneration under section 40(b), book profit is the net profit shown in the profit and loss account, subject only to statutory adjustments, so interest on fixed deposits kept for business facilities was included in book profit. Ad hoc disallowances were then dealt with separately: travelling expense disallowance and accrued interest addition were deleted, business promotion disallowance was partly sustained, and staff welfare and entertainment disallowance was sustained.</description>
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