https://www.taxtmi.com/caselaws?id=37532 Reopening under section 34(1)(b) was held invalid because the facts about the purchases were already before the assessing officer, and a later appreciation of their legal effect did not amount to fresh information justifying reassessment. Profit apportionment under sections 42(1) and 42(3) was also rejected because the purchases in Part A and Part C States were not shown to constitute a definite, commercially identifiable business operation in the taxable territories or to yield an attributable profit margin. On both issues, the reference was answered against the revenue and in favour of the assessee. en-us Mon, 27 Feb 1978 00:00:00 +0530 Tue, 30 Mar 2010 13:18:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=37532 Reopening under section 34(1)(b) was held invalid because the facts about the purchases were already before the assessing officer, and a later appreciation of their legal effect did not amount to fresh information justifying reassessment. Profit apportionment under sections 42(1) and 42(3) was also rejected because the purchases in Part A and Part C States were not shown to constitute a definite, commercially identifiable business operation in the taxable territories or to yield an attributable profit margin. On both issues, the reference was answered against the revenue and in favour of the assessee. Case-Laws Income Tax Mon, 27 Feb 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=37532