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In the result, appeals are dismissed
Bench: Shri Saktijit Dey & Shri G. Manjunatha
section 80IA of the Act was made only on the basis of the reasoning on which such disallowance was made in the original assessment order. Thus, the leaned Sr. Counsel submitted, since the impugned assessment year is a case unabated assessment, no addition / disallowance could have been made without any incriminating material concerning such issue. The leaned Sr. Counsel submitted