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The Tax PublishersITA Nos. 839/Bang/2015 & 170/Bang/2016
2021 TaxPub(DT) 0027 (Bang-Trib)INCOME TAX ACT, 1961
Section 147
Reopening had been rightly quashed by CIT(A) as issue regarding production expenditure claimed by assessee for one assessment year had been remanded to AO for fresh consideration and for another assessment year assessee did not claim any expenses under production cost.
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Reassessment - Validity - No failure on part of assessee to fully and truly disclose all material facts -
Revenue was in appeal challenging reassessment quashed by CIT(A) on the ground that assessee did not produce any evidence to claim expenses towards the production cost incurred during the years under consideration and failed to substantiate the difference in the production cost adopted in the return of income filed and Form 52A filed in spite of opportunity of being heard granted to assessee. Held: It is an admitted position that production cost claimed by assessee for one year was remanded by Tribunal to AO for fresh consideration and for another year assessee had not claimed production cost as expenditure. It was noted that production cost had been considered as work-in-progress. Therefore, no merit could be found in the appeals filed by revenue for years under consideration.
REFERRED :
FAVOUR : In favour of assessee.
A.Y. :
IN THE ITAT, BANGALORE BENCH
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