SEZ profit deduction and interest nexus challenged in reopened assessment; s.139(4) return accepted, reassessment quashed

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....Reopening of assessment to withdraw deduction was held invalid because the original assessment had merged with an appellate order and the AO, acting on supervisory direction, lacked independent "reason to believe"; further, the recorded reasons did not allege failure to fully and truly disclose material facts, a jurisdictional precondition for reopening beyond four years, so the reassessment was set aside. Deduction under Chapter VI-A was held allowable despite a return filed within the extended time under s.139(4), applying the rule that conflicting views be resolved in favour of the taxpayer, so denial on belated filing was rejected. Interest and allied receipts were treated as having direct nexus with SEZ business, so deduction was susta.........