Reassessment u/s 147 Invalidated; Section 80(IB)(10)(d) Applies Prospectively, No Completion Certificate Needed Within Four Years.

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....Reopening of assessment u/s 147 - Section 80(IB)(10)(d) will be applicable prospectively - there is no such condition to have completion certificate within four years from the local authority granting approval of the projects in question, the reassessment proceedings taken against the assessee are bad and against the settled principle of law - re-assessment rightly set aside....