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    <title>2024 (10) TMI 537 - ITAT DELHI</title>
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    <description>The ITAT Delhi quashed reassessment proceedings initiated beyond four years where the assessee had fully disclosed export incentive and foreign exchange fluctuation as business income in the original return. The AO completed assessment under section 143(3) accepting the return, and later issued notice under section 154 based on audit objection regarding section 80IC deduction but passed no rectification order. Since all material facts were disclosed during original assessment and no new material emerged after four years indicating escaped assessment, the reopening was invalid. The tribunal deleted additions made by AO and confirmed by CIT(A), ruling in favor of the assessee.</description>
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    <pubDate>Wed, 09 Oct 2024 00:00:00 +0530</pubDate>
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      <title>2024 (10) TMI 537 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=759938</link>
      <description>The ITAT Delhi quashed reassessment proceedings initiated beyond four years where the assessee had fully disclosed export incentive and foreign exchange fluctuation as business income in the original return. The AO completed assessment under section 143(3) accepting the return, and later issued notice under section 154 based on audit objection regarding section 80IC deduction but passed no rectification order. Since all material facts were disclosed during original assessment and no new material emerged after four years indicating escaped assessment, the reopening was invalid. The tribunal deleted additions made by AO and confirmed by CIT(A), ruling in favor of the assessee.</description>
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