Revisionary proceedings u/s 263 against reassessment proceedings are confined to reasons recorded u/s 148

Facts:

The assessment year involved in this case is AY 2009-10. The regular assessment u/ 143(3) r.w.s. 144C was completed on 16/01/2014 for the said assessment year. Subsequently, the Ld. Assessing Officer initiate the reassessment proceedings of very same assessment year during the FY 2016-17. Reasons were recorded with respect to disallowance of claim of the assessee u/s 80IA and 80IB on account of;

• captive power plant does not qualify as an “industrial undertakin

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