Punjab & Haryana H.C : Reopening beyond 4 years from the assessment year was bad in law as the assessee has not failed to disclose truly and fully all material facts necessary for assessment, despite the fact that the treatment of service income for the purpose of calculation of deduction u/s 80 HHC was not discussed at any prior stage, and the assessee had made no clear submission in this regard in earlier proceedings

High Court Of Punjab And Haryana CIT, Faridabad vs. ITW India Ltd. Assessment Years : 2002-03 To 2004-05 Section : 80HHC, 147 S.J. Vajifdar, ACTG.CJ. And G.S. Sandhawalia, J. IT Appeal Nos. 207, 208 & 227 Of 2014 July 15, 2015 JUDGMENT G.S. Sandhawalia, J. – The present judgment shall dispose of three appeals which…

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