https://www.taxtmi.com/caselaws?id=195325 Reassessment under sections 147/148 was upheld because it was based on fresh tangible material from a Tribunal finding in another proceeding, so it was not a mere change of opinion. Deduction under section 80IA(4) was allowed because the assessee was treated as the developer of the infrastructure facility and the toll operator's profits were regarded as arising under a separate contractual arrangement, avoiding double deduction of the same profit element. The claim for loss on the abandoned Jhalawar-Indore road project was treated as revenue in nature but was disallowed in the year under appeal because the loss had not crystallised by that year; the assessee was left free to claim it in the year of crystallisation. en-us Thu, 13 Apr 2017 00:00:00 +0530 Thu, 26 Oct 2017 08:33:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=195325 Reassessment under sections 147/148 was upheld because it was based on fresh tangible material from a Tribunal finding in another proceeding, so it was not a mere change of opinion. Deduction under section 80IA(4) was allowed because the assessee was treated as the developer of the infrastructure facility and the toll operator's profits were regarded as arising under a separate contractual arrangement, avoiding double deduction of the same profit element. The claim for loss on the abandoned Jhalawar-Indore road project was treated as revenue in nature but was disallowed in the year under appeal because the loss had not crystallised by that year; the assessee was left free to claim it in the year of crystallisation. Case-Laws Income Tax Thu, 13 Apr 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=195325