2018 (4) TMI 194

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....ioner. Mr. N.N. Singh, Advocate for Respondents . P.C: 1. Heard. 2. Rule. 3. This Petition challenges the notice dated 31.3.2017 issued under Section 148 of the Act seeking to reopen the assessment for the Assessment Year 2010-11. The regular assessment proceedings for the subject Assessment Year was completed on 18.3.2014 under Section 143(3) of the Act. Admittedly, the impugned....

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.... 4. Moreover, we find that the reasons for the impugned notice is based upon the excessive grant of deduction under Section 10B of the Act during the regular assessment proceedings. This on account of notional foreign exchange gain was taken into account while determining the profits under Section 10B of the Act in respect of its Export Oriented Unit. During the regular assessment proceedings, ....