Case Law Details
Case Name : United Phosphorus Ltd. Vs. Additional Commissioner Of Income Tax (Gujarat High Court)
Related Assessment Year : 1966-97
Courts :
All High Courts Gujarat High Court
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From the reasons recorded, it is apparent that the Assessing Officer has reopened the assessment mainly on three grounds. Firstly, that the income referred to in the said ground viz., income from rent, export incentive, advance licence benefit receivable, pass book benefit receivable, exchange rate difference, refund of sales tax, refund of electricity duty, excess provision in respect of earlier years written back, sundry credit balances written back interest income, discount, miscellaneous, which had been taken into consideration for deduction under section 80IA of the Act, does not fall
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Its a clear case of mere change of opinion as the all the issues were discussed in assessment and no new facts brought on record.