Allowing the petition the Court held that entire issue with regard to interest income on funds collected as R & D and R & M funds was decided against assessee and was pending decision before Commissioner (Appeals), reopening of assessment was mere change of opinion of Assessing Officer about manner of computation of deduction under section 80AI, hence, not justified. (AY. 2015-16)
Nuclear Power Corporation of India Ltd. v. DCIT [2023] 151 taxmann.com 537 (Bom)(HC)
S. 147 : Reassessment–After the expiry of four years – Interest on funds collected–Issue pending before the Commissioner (Appeals)- Reassessment notice and order disposing the objection was quashed. [S. 80IA, 148, 250, Art. 226]