https://www.taxtmi.com/caselaws?id=239250 The reassessment proceedings initiated by the Assessing Officer under section 147 of the Income Tax Act were deemed invalid by the Tribunal as they were based on a mere change of opinion without new tangible material. Consequently, the reassessment order was annulled. The dispute regarding the exclusion of expenditure incurred in foreign exchange from export turnover for deduction under section 10A and the allocation of expenditure between software development and technical services were not addressed in detail due to the annulment of the reassessment proceedings. The appeal by the assessee was allowed, and the appeal by the revenue was dismissed. en-us Mon, 30 Sep 2013 00:00:00 +0530 Sat, 09 Nov 2013 09:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=239250 The reassessment proceedings initiated by the Assessing Officer under section 147 of the Income Tax Act were deemed invalid by the Tribunal as they were based on a mere change of opinion without new tangible material. Consequently, the reassessment order was annulled. The dispute regarding the exclusion of expenditure incurred in foreign exchange from export turnover for deduction under section 10A and the allocation of expenditure between software development and technical services were not addressed in detail due to the annulment of the reassessment proceedings. The appeal by the assessee was allowed, and the appeal by the revenue was dismissed. Case-Laws Income Tax Mon, 30 Sep 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=239250