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    <title>2025 (3) TMI 1805 - ITAT AHMEDABAD</title>
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    <description>Reassessment beyond four years was held unsustainable because the recorded reasons did not show any failure by the assessee to fully and truly disclose all material facts; the original assessment had already considered the deduction claim and audit report, so the notice under section 148 was invalid. On the deduction issue, section 80IA was applied by linking computation to the assessee&#039;s chosen initial assessment year, and earlier years&#039; losses already absorbed could not be notionally carried forward again to reduce the claim. The Revenue&#039;s objection therefore failed, and the deduction could not be disallowed on that basis.</description>
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      <title>2025 (3) TMI 1805 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=469473</link>
      <description>Reassessment beyond four years was held unsustainable because the recorded reasons did not show any failure by the assessee to fully and truly disclose all material facts; the original assessment had already considered the deduction claim and audit report, so the notice under section 148 was invalid. On the deduction issue, section 80IA was applied by linking computation to the assessee&#039;s chosen initial assessment year, and earlier years&#039; losses already absorbed could not be notionally carried forward again to reduce the claim. The Revenue&#039;s objection therefore failed, and the deduction could not be disallowed on that basis.</description>
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