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    <title>2011 (3) TMI 1720 - ITAT PUNE</title>
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    <description>The Tribunal validated the reopening of the assessment under Section 147, finding the reasons recorded were adequate. The issue of enhancement without issuing a mandatory notice under Section 251(2) was remanded for further examination. The denial of exemption under Section 11 due to the acquisition of shares in a cooperative bank was upheld but restricted to income related to the shares. The Tribunal allowed the claim under Section 36(1)(va) based on the Supreme Court&#039;s decision in Alom Extrusions Ltd. The matter of disallowance under Section 40A(3) was remanded for reconsideration, and capital expenses were deemed revenue in nature. The treatment of donations towards the trust corpus was sent back for fresh adjudication.</description>
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      <link>https://www.taxtmi.com/caselaws?id=190972</link>
      <description>The Tribunal validated the reopening of the assessment under Section 147, finding the reasons recorded were adequate. The issue of enhancement without issuing a mandatory notice under Section 251(2) was remanded for further examination. The denial of exemption under Section 11 due to the acquisition of shares in a cooperative bank was upheld but restricted to income related to the shares. The Tribunal allowed the claim under Section 36(1)(va) based on the Supreme Court&#039;s decision in Alom Extrusions Ltd. The matter of disallowance under Section 40A(3) was remanded for reconsideration, and capital expenses were deemed revenue in nature. The treatment of donations towards the trust corpus was sent back for fresh adjudication.</description>
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