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    <title>2019 (1) TMI 1410 - ITAT VISAKHAPATNAM</title>
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    <description>For deduction under section 80IA, the profit of a captive power undertaking was computed by valuing power transferred for internal consumption at its market value, and the lower rate suggested by the Revenue was rejected. The Tribunal followed its earlier view in the assessee&#039;s own case and upheld the deduction on the basis adopted by the CIT(A). Reopening under section 148 was treated as a mere change of opinion because it rested on the same material without fresh tangible material, so the reassessment could not be sustained. The Revenue&#039;s appeals failed on both issues, and the assessee&#039;s cross-objections became infructuous.</description>
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      <link>https://www.taxtmi.com/caselaws?id=374245</link>
      <description>For deduction under section 80IA, the profit of a captive power undertaking was computed by valuing power transferred for internal consumption at its market value, and the lower rate suggested by the Revenue was rejected. The Tribunal followed its earlier view in the assessee&#039;s own case and upheld the deduction on the basis adopted by the CIT(A). Reopening under section 148 was treated as a mere change of opinion because it rested on the same material without fresh tangible material, so the reassessment could not be sustained. The Revenue&#039;s appeals failed on both issues, and the assessee&#039;s cross-objections became infructuous.</description>
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