https://www.taxtmi.com/caselaws?id=783990 Reassessment proceedings were quashed as time-barred because the Revenue had no new tangible material beyond the original return and financial statements, making the reopening an impermissible review, and the extended limitation under the proviso to s.147 was unavailable absent any failure of full and true disclosure; limitation ran from the original s.143(3) assessment since a later s.143(3) r/w s.263 order confined to s.10A/10B computation did not merge on the depreciation issue, so jurisdiction was assumed beyond time. On depreciation, "computer software" was held eligible for 60% for the relevant pre-AY 2003-04 period under the then entry for "computers," there being no separate software entry and the claim having been consistently accepted; both issues were decided in favour of the assessee. en-us Fri, 19 Dec 2025 00:00:00 +0530 Fri, 26 Dec 2025 07:18:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783990 Reassessment proceedings were quashed as time-barred because the Revenue had no new tangible material beyond the original return and financial statements, making the reopening an impermissible review, and the extended limitation under the proviso to s.147 was unavailable absent any failure of full and true disclosure; limitation ran from the original s.143(3) assessment since a later s.143(3) r/w s.263 order confined to s.10A/10B computation did not merge on the depreciation issue, so jurisdiction was assumed beyond time. On depreciation, "computer software" was held eligible for 60% for the relevant pre-AY 2003-04 period under the then entry for "computers," there being no separate software entry and the claim having been consistently accepted; both issues were decided in favour of the assessee. Case-Laws Income Tax Fri, 19 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783990