https://www.taxtmi.com/caselaws?id=61244 The Tribunal ruled in favor of the assessee, overturning the AAC's decision and allowing both appeals. It found that the revenue's initiation of sections 147(b) proceedings was unwarranted and contrary to the law. The Tribunal emphasized that the audit objection, which led to the reduction of the development rebate percentage, did not justify reopening the assessment under sections 147(b). The decision highlighted the importance of distinguishing between sections 147(b) and 154 proceedings and upheld the assessee's position based on previous favorable outcomes in similar cases. en-us Tue, 28 Dec 1982 00:00:00 +0530 Tue, 11 Jan 2011 14:28:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=61244 The Tribunal ruled in favor of the assessee, overturning the AAC's decision and allowing both appeals. It found that the revenue's initiation of sections 147(b) proceedings was unwarranted and contrary to the law. The Tribunal emphasized that the audit objection, which led to the reduction of the development rebate percentage, did not justify reopening the assessment under sections 147(b). The decision highlighted the importance of distinguishing between sections 147(b) and 154 proceedings and upheld the assessee's position based on previous favorable outcomes in similar cases. Case-Laws Income Tax Tue, 28 Dec 1982 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=61244