ARRDY ENGINNERING INNOVATIONS (P) LTD,ROURKELA vs. THE ACIT, CIRCLE - 3(1), VISAKHAPATNAM., VISAKHAPATNAM
In the result, appeal of the assessee is allowed
ITA 432/VIZ/2012[2007-2008]Status: DisposedITAT Visakhapatnam28 Feb 2024AY 2007-2008
Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble
For Appellant: Sri GVN Hari, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 143(3)Section 147Section 148Section 35Section 35(1)Section 35(1)(i)Section 35(1)(iv)Section 35(2)(ia)Section 40
reassessment proceedings U/s. 147 is not permissible merely on the basis of change of opinion because the AO for subsequent AY 2006-07 had taken a view that weighted deduction U/s. 35(2AB) cannot be allowed.
3. Even assuming (without admitting) that appellant was not eligible for weighted deduction U/s. 35(2AB) in respect of R&D expenditure towards field