https://www.taxtmi.com/caselaws?id=460095 ITAT Jaipur upheld AO's jurisdiction to reopen assessment u/s 147 regarding s. 80IA deduction, finding assessee failed to disclose material facts about head office expense apportionment during original assessment. Tribunal rejected assessee's contention that corporate office expenses had no nexus with eligible undertakings, ruling strategic and managerial activities require expense allocation. However, certain expenses like rates, taxes, insurance, and interest on debentures were excluded as having no nexus with energy generation units. Matter remanded to AO for recalculation of eligible profits with proper expense allocation based on turnover ratio. Appeal partly allowed for statistical purposes. en-us Mon, 05 Nov 2018 00:00:00 +0530 Fri, 10 Jan 2025 20:17:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460095 ITAT Jaipur upheld AO's jurisdiction to reopen assessment u/s 147 regarding s. 80IA deduction, finding assessee failed to disclose material facts about head office expense apportionment during original assessment. Tribunal rejected assessee's contention that corporate office expenses had no nexus with eligible undertakings, ruling strategic and managerial activities require expense allocation. However, certain expenses like rates, taxes, insurance, and interest on debentures were excluded as having no nexus with energy generation units. Matter remanded to AO for recalculation of eligible profits with proper expense allocation based on turnover ratio. Appeal partly allowed for statistical purposes. Case-Laws Income Tax Mon, 05 Nov 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460095