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    <title>2016 (11) TMI 1552 - ITAT KOLKATA</title>
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    <description>The Tribunal ruled in favor of the assessee on all grounds. The reassessment proceedings initiated under Section 147 were deemed invalid due to being based solely on a change of opinion and issued beyond the permissible period. The interest income was considered business income, qualifying for exemption under Section 10B. Additionally, the blending of tea was recognized as manufacturing, entitling the assessee to the Section 10B exemption. As a result, the assessee&#039;s appeals were allowed, and the revenue&#039;s appeals were dismissed.</description>
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    <pubDate>Fri, 18 Nov 2016 00:00:00 +0530</pubDate>
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      <title>2016 (11) TMI 1552 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=272792</link>
      <description>The Tribunal ruled in favor of the assessee on all grounds. The reassessment proceedings initiated under Section 147 were deemed invalid due to being based solely on a change of opinion and issued beyond the permissible period. The interest income was considered business income, qualifying for exemption under Section 10B. Additionally, the blending of tea was recognized as manufacturing, entitling the assessee to the Section 10B exemption. As a result, the assessee&#039;s appeals were allowed, and the revenue&#039;s appeals were dismissed.</description>
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      <pubDate>Fri, 18 Nov 2016 00:00:00 +0530</pubDate>
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