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    <title>2025 (11) TMI 1616 - GUJARAT HIGH COURT</title>
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    <description>HC held that the assessee was not entitled to special deduction under s.42 for mineral oil prospecting, following the SC ruling in Joshi Technologies International Inc., which restricts assessment strictly to the terms of the Production Sharing Contract (PSC). As the PSC did not support the claimed deductions, the Assessing Officer was right in denying them. On reopening, HC found that the reassessment was valid, as there had been no prior scrutiny of the s.42 claim and hence no mere change of opinion, rendering remand to the Tribunal unnecessary.</description>
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      <title>2025 (11) TMI 1616 - GUJARAT HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=782148</link>
      <description>HC held that the assessee was not entitled to special deduction under s.42 for mineral oil prospecting, following the SC ruling in Joshi Technologies International Inc., which restricts assessment strictly to the terms of the Production Sharing Contract (PSC). As the PSC did not support the claimed deductions, the Assessing Officer was right in denying them. On reopening, HC found that the reassessment was valid, as there had been no prior scrutiny of the s.42 claim and hence no mere change of opinion, rendering remand to the Tribunal unnecessary.</description>
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      <pubDate>Thu, 13 Nov 2025 00:00:00 +0530</pubDate>
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