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In favour of revenue.In view of the forgoing decision, we are of the view that the reopening of the assessment under s. 147, r/w s. 150, was within the period of limitation.

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Section 147, 149, 150 & 153(1) of the Income Tax Act, 1961 — Reassessment — Tribunal has for the AY 2008-09 held that the assessee's Selaqui unit for which deduction under section 80IC was sought did not carry on any manufacturing activity and it was not entitled to deduction. finding given by Tribunal strikes at the foundation of the claim of the assessee that Selaqui unit is entitled to deduction under section 80IC for the immediate succeeding year in question. finding in this case cannot be considered as relevant and limited only to A.Y. 2008-09. findings would also be relevant for A.Y. 2009-10. reopening of the assessment under section 147 read with section 150 was valid and within the period of limitation — Intec Corporation vs. Assistant Commissioner of income tax [2020] 312 CTR Delhi 3

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