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    <title>2016 (3) TMI 271 - ITAT DELHI</title>
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    <description>The Tribunal ruled in favor of the appellant in a case involving reassessment proceedings under sections 147/148 of the Income Tax Act, 1961. The reassessment was deemed invalid as it was based on a mere change of opinion without tangible material indicating income escapement. The appellant was allowed the deduction under Section 80-IA, and expenses related to power generation income were considered genuine and necessary, overturning the disallowance by the Assessing Officer. Additionally, supervision, erection, and commissioning charges were classified as revenue expenses, leading to a favorable outcome for the appellant.</description>
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      <link>https://www.taxtmi.com/caselaws?id=325087</link>
      <description>The Tribunal ruled in favor of the appellant in a case involving reassessment proceedings under sections 147/148 of the Income Tax Act, 1961. The reassessment was deemed invalid as it was based on a mere change of opinion without tangible material indicating income escapement. The appellant was allowed the deduction under Section 80-IA, and expenses related to power generation income were considered genuine and necessary, overturning the disallowance by the Assessing Officer. Additionally, supervision, erection, and commissioning charges were classified as revenue expenses, leading to a favorable outcome for the appellant.</description>
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