https://www.taxtmi.com/caselaws?id=56206 An assessment under section 8(b) of the Companies (Profits) Surtax Act, 1964 cannot be reopened on the basis of an internal audit objection where the original material was already on record and the attempt rests only on a change of opinion, not legally relevant new information. For capital computation, the reduction of the statutory deduction base by amounts linked to paid-up capital and reserve adjustment was held unjustified on the facts, because the excess development rebate reserve had to be treated in accordance with the governing CBDT circular and the surtax scheme. The revised surtax assessment was therefore set aside in favour of the assessee. en-us Mon, 02 Feb 1987 00:00:00 +0530 Thu, 02 Dec 2010 13:03:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=56206 An assessment under section 8(b) of the Companies (Profits) Surtax Act, 1964 cannot be reopened on the basis of an internal audit objection where the original material was already on record and the attempt rests only on a change of opinion, not legally relevant new information. For capital computation, the reduction of the statutory deduction base by amounts linked to paid-up capital and reserve adjustment was held unjustified on the facts, because the excess development rebate reserve had to be treated in accordance with the governing CBDT circular and the surtax scheme. The revised surtax assessment was therefore set aside in favour of the assessee. Case-Laws Income Tax Mon, 02 Feb 1987 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=56206