Assessment Earnings Avoidance Assessment is engaged in the ITO Carpet and Drug Export business, deducting interest on fixed deposit receipts under Section 80HC for the year 1988. Reasons to reopen 87 assessments following the Tribunal's decision for the exemption, estimation 1986, under section 80HC, do not state that the receipts received in 1988 were the same as those on which interest was earned in 1986. 87 Tribunals assessment 1986 The search of the year 87 cannot be adopted mechanically for the year 1988 898 There is no reason for the ITO to believe that other sources of interest for 1988 89 may also be assessed. Was to be used as income from the re-review under review options. The Taxes Act, 1961, Sections 147 and 148
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