https://www.taxtmi.com/caselaws?id=178651 The Tribunal held that the reopening of assessment under sections 147/148 lacked tangible material and constituted a change of opinion, citing the judgment of the Delhi High Court. It emphasized the necessity of a live link between reasons and beliefs for such reopening. Regarding the allowability of deduction under section 10A, the Tribunal agreed with the appellant that the deduction should be allowed before setting off brought forward losses and should be calculated on a unit-wise basis. The Tribunal upheld the CIT(A)'s order, stating that the Assessing Officer's actions amounted to a change of opinion without sufficient grounds, leading to the dismissal of the Revenue's appeal. en-us Fri, 20 May 2011 00:00:00 +0530 Wed, 10 Feb 2016 12:10:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=178651 The Tribunal held that the reopening of assessment under sections 147/148 lacked tangible material and constituted a change of opinion, citing the judgment of the Delhi High Court. It emphasized the necessity of a live link between reasons and beliefs for such reopening. Regarding the allowability of deduction under section 10A, the Tribunal agreed with the appellant that the deduction should be allowed before setting off brought forward losses and should be calculated on a unit-wise basis. The Tribunal upheld the CIT(A)'s order, stating that the Assessing Officer's actions amounted to a change of opinion without sufficient grounds, leading to the dismissal of the Revenue's appeal. Case-Laws Income Tax Fri, 20 May 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=178651