https://www.taxtmi.com/caselaws?id=216170 The appellant, an exporter of cashew kernels, contested the disallowance of deduction claimed under Section 80 HHC for profit on sale of DEPB due to a 2005 amendment affecting exporters with turnover exceeding Rs.10 crores. The appellate authorities upheld the reopening of assessment under Section 147 based on the retrospective amendment, citing jurisdiction limitations. The Tribunal's focus on the reopening under Section 147 was supported by the Supreme Court judgment on DEPB sale value treatment. The Court concluded that challenging the constitutional validity of the 2005 amendment exceeded the Tribunal's jurisdiction under Section 260A, leading to the rejection of the appeals. en-us Fri, 03 Aug 2012 00:00:00 +0530 Tue, 28 Aug 2012 14:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=216170 The appellant, an exporter of cashew kernels, contested the disallowance of deduction claimed under Section 80 HHC for profit on sale of DEPB due to a 2005 amendment affecting exporters with turnover exceeding Rs.10 crores. The appellate authorities upheld the reopening of assessment under Section 147 based on the retrospective amendment, citing jurisdiction limitations. The Tribunal's focus on the reopening under Section 147 was supported by the Supreme Court judgment on DEPB sale value treatment. The Court concluded that challenging the constitutional validity of the 2005 amendment exceeded the Tribunal's jurisdiction under Section 260A, leading to the rejection of the appeals. Case-Laws Income Tax Fri, 03 Aug 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=216170