https://www.taxtmi.com/caselaws?id=310299 The Tribunal invalidated the reopening of the assessment under section 148, as it was based on a change of opinion and occurred beyond four years without any failure by the assessee to disclose material facts. The Tribunal allowed the deduction under section 80IA, finding that the conditions were met. The Tribunal also directed the deletion of the penalty under section 271(1)(c) since the addition under section 80IA did not survive. Other issues, including levying interest under sections 234B and 234D and computation of book profits, were rendered academic due to the primary decision on reopening. en-us Mon, 28 Feb 2022 00:00:00 +0530 Wed, 18 Oct 2023 05:30:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=310299 The Tribunal invalidated the reopening of the assessment under section 148, as it was based on a change of opinion and occurred beyond four years without any failure by the assessee to disclose material facts. The Tribunal allowed the deduction under section 80IA, finding that the conditions were met. The Tribunal also directed the deletion of the penalty under section 271(1)(c) since the addition under section 80IA did not survive. Other issues, including levying interest under sections 234B and 234D and computation of book profits, were rendered academic due to the primary decision on reopening. Case-Laws Income Tax Mon, 28 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=310299