https://www.taxtmi.com/caselaws?id=783804 Reopening under ss.147/148 to withdraw deduction was held invalid because the original assessment had merged with the appellate order, the AO acted on a superior's direction rather than forming an independent "reason to believe," and the recorded reasons did not allege failure to fully and truly disclose material facts for reopening beyond four years; the reassessment was set aside. Deduction under ss.80IAB/80IC/80IB was held allowable where the return was filed within the extended time under s.139(4); in the face of divergent HC views, the interpretation favourable to the assessee was adopted, and the deduction was granted. Interest on bank deposits and allied receipts were treated as having direct business nexus with SEZ operations; revenue's challenge was dismissed. Disallowances for excess depreciation and lease rent/TDS were directed to be allowed, as 100% deduction under s.80IAB rendered the adjustments tax-neutral per CBDT Circular No.37/2016. en-us Fri, 12 Dec 2025 00:00:00 +0530 Tue, 23 Dec 2025 07:59:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783804 Reopening under ss.147/148 to withdraw deduction was held invalid because the original assessment had merged with the appellate order, the AO acted on a superior's direction rather than forming an independent "reason to believe," and the recorded reasons did not allege failure to fully and truly disclose material facts for reopening beyond four years; the reassessment was set aside. Deduction under ss.80IAB/80IC/80IB was held allowable where the return was filed within the extended time under s.139(4); in the face of divergent HC views, the interpretation favourable to the assessee was adopted, and the deduction was granted. Interest on bank deposits and allied receipts were treated as having direct business nexus with SEZ operations; revenue's challenge was dismissed. Disallowances for excess depreciation and lease rent/TDS were directed to be allowed, as 100% deduction under s.80IAB rendered the adjustments tax-neutral per CBDT Circular No.37/2016. Case-Laws Income Tax Fri, 12 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783804