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    <description>The Tribunal upheld the validity of reopening the assessment under Section 147 of the Income Tax Act, as the reassessment was based on tangible materials not considered in the original assessment. However, the compensation received for termination of a manufacturing agreement was deemed a capital receipt, not taxable under Section 28(va)(a), as it pertained to loss of a source of income rather than non-compete fees. The Tribunal directed the deletion of the addition made by the Assessing Officer, following the decision in CIT vs. Parle Soft Drinks (Bangalore) P. Ltd.</description>
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