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    <title>2023 (7) TMI 1032 - ITAT DELHI</title>
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    <description>The reassessment proceedings initiated under section 148 of the Income Tax Act were deemed void ab initio as they did not meet the prescribed conditions, resulting in the assessee&#039;s appeal being allowed and the Revenue&#039;s appeal being dismissed. Disallowances of rebate and discounts, expenditure in foreign currency, and additional depreciation were found unjustified, leading to the allowance of the assessee&#039;s appeals. However, disallowances on &#039;know-how&#039; and professional charges and &#039;prior period expenditure&#039; were upheld, with the Revenue&#039;s appeal being dismissed regarding the deletion of addition under section 41(1) of the Act due to failure to meet necessary conditions.</description>
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      <description>The reassessment proceedings initiated under section 148 of the Income Tax Act were deemed void ab initio as they did not meet the prescribed conditions, resulting in the assessee&#039;s appeal being allowed and the Revenue&#039;s appeal being dismissed. Disallowances of rebate and discounts, expenditure in foreign currency, and additional depreciation were found unjustified, leading to the allowance of the assessee&#039;s appeals. However, disallowances on &#039;know-how&#039; and professional charges and &#039;prior period expenditure&#039; were upheld, with the Revenue&#039;s appeal being dismissed regarding the deletion of addition under section 41(1) of the Act due to failure to meet necessary conditions.</description>
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