https://www.taxtmi.com/caselaws?id=14808 The dispute concerned whether an assessee could create an additional reserve to claim a higher deduction under section 80HHC after the deduction was enhanced in assessment, and whether any substantial question of law arose from the revisional order under section 263. The Bombay HC found that the assessee had sufficient opportunity to create the reserve when the assessment resulted in a higher deduction and after notice under section 263, but failed to do so. It treated the inability-to-foresee argument as fact-specific and held that the development rebate precedent was inapplicable to section 80HHC. The matter was held to turn on pure findings of fact, so no substantial question of law arose and the assessee did not succeed. en-us Mon, 14 Feb 2000 00:00:00 +0530 Thu, 23 Aug 2018 15:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=14808 The dispute concerned whether an assessee could create an additional reserve to claim a higher deduction under section 80HHC after the deduction was enhanced in assessment, and whether any substantial question of law arose from the revisional order under section 263. The Bombay HC found that the assessee had sufficient opportunity to create the reserve when the assessment resulted in a higher deduction and after notice under section 263, but failed to do so. It treated the inability-to-foresee argument as fact-specific and held that the development rebate precedent was inapplicable to section 80HHC. The matter was held to turn on pure findings of fact, so no substantial question of law arose and the assessee did not succeed. Case-Laws Income Tax Mon, 14 Feb 2000 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=14808