Reassessment on ground of allowance of excess deduction on incentives of DEPB U/s. 80HHC

RELEVANT PARAGRAPH 7. We have considered the issue. The learned CIT (A) has considered that there was a change of opinion by the A.O. and he deemed to have formed an opinion at the time of original assessment on allowing 80HHC deduction on DEPB. There is nothing on record to support the opinion formed by the learned CIT(A) on this issue. The learned counsel during the present proceedings could not point out any show cause letter or clarification sought by the A.O. on the issue of DEPB income and has relied on only legal issues before us. There is no evidence that the A.O. has at least sought c...