https://www.taxtmi.com/caselaws?id=446772 Reopening under s.147 to deny deduction u/s 10A was held invalid. ITAT found no new material showing nondisclosure by the assessee; the AO relied on an inference drawn in A.Y. 2009-10 about export/service character, but that inference was erroneous and later reversed by the Tribunal. Because the facts relied upon were already on record and merely produced a different view in a subsequent year, there was no failure to disclose material facts for A.Y. 2006-07 (and 2007-08). Reopening and resultant additions were set aside; decision for the assessee. en-us Thu, 30 Nov 2023 00:00:00 +0530 Sat, 11 Oct 2025 13:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446772 Reopening under s.147 to deny deduction u/s 10A was held invalid. ITAT found no new material showing nondisclosure by the assessee; the AO relied on an inference drawn in A.Y. 2009-10 about export/service character, but that inference was erroneous and later reversed by the Tribunal. Because the facts relied upon were already on record and merely produced a different view in a subsequent year, there was no failure to disclose material facts for A.Y. 2006-07 (and 2007-08). Reopening and resultant additions were set aside; decision for the assessee. Case-Laws Income Tax Thu, 30 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446772