https://www.taxtmi.com/caselaws?id=451042 The ITAT Chennai quashed reassessment proceedings initiated beyond four years for deduction under section 80IA. The Tribunal held that the issue had attained finality through doctrine of merger, as the CIT(A)'s order was confirmed by the Tribunal and HC did not admit revenue's appeal. The AO failed to establish reasons based on tangible material indicating income escapement and did not record that the assessee failed to disclose material facts necessary for assessment beyond four years. The reopening was merely based on revenue audit objection without fulfilling mandatory conditions. The assessment order was accordingly quashed as bad-in-law. en-us Wed, 13 Mar 2024 00:00:00 +0530 Tue, 19 Mar 2024 08:41:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=451042 The ITAT Chennai quashed reassessment proceedings initiated beyond four years for deduction under section 80IA. The Tribunal held that the issue had attained finality through doctrine of merger, as the CIT(A)'s order was confirmed by the Tribunal and HC did not admit revenue's appeal. The AO failed to establish reasons based on tangible material indicating income escapement and did not record that the assessee failed to disclose material facts necessary for assessment beyond four years. The reopening was merely based on revenue audit objection without fulfilling mandatory conditions. The assessment order was accordingly quashed as bad-in-law. Case-Laws Income Tax Wed, 13 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=451042