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Issues Involved:
1. Cancellation of reassessments under section 147 beyond the period of four years. 2. Admission of fresh claim for deduction under section 80HHA without a reasonable opportunity of being heard by the Assessing Officer. Detailed Analysis: Issue 1: Cancellation of reassessments under section 147 beyond the period of four years The Revenue challenged the cancellation of reassessments for the assessment years 1992-93 and 1993-94 by CIT(A), who held that there was no omission or failure on the part of the assessee to disclose all material facts necessary for making the assessments. The original assessments were completed under section 143(3) and allowed deductions under sections 80HH, 80-I, and 80HHC. The Assessing Officer later noticed that the assessee had claimed and was allowed deductions under section 80HHA for preceding years, which should have precluded deductions under sections 80HH and 80-I for the same or subsequent years. Consequently, the Assessing Officer initiated reassessment proceedings under section 148, withdrawing the deductions. The CIT(A) observed that the original assessments had been completed after calling for and receiving all necessary particulars regarding the deductions. The assessee had disclosed fully and truly all material facts, and the reassessments were initiated beyond the permissible period of four years. Therefore, the CIT(A) concluded that the reopening of assessments was not in order and cancelled the reassessments. The Tribunal upheld the CIT(A)'s decision, stating that the initiation of reassessment proceedings was beyond the period of limitation as per the proviso to section 147. The Tribunal emphasized that the assessee had disclosed all material facts necessary for the assessments, which were scrutinized by the Assessing Officer during the original assessments under section 143(3). Hence, there was no failure on the part of the assessee to disclose material facts fully and truly, and the reassessment proceedings were invalid. Issue 2: Admission of fresh claim for deduction under section 80HHA without a reasonable opportunity of being heard by the Assessing Officer The second issue raised by the Revenue was whether the CIT(A) erred in admitting a fresh claim for deduction under section 80HHA without allowing a reasonable opportunity of being heard to the Assessing Officer. The Tribunal noted that the CIT(A) had decided the appeal on the issue of jurisdiction for reopening the assessments and cancelled the reassessments on that basis. Since the reassessments were declared invalid, the other issue regarding the fresh claim for deduction under section 80HHA did not survive. Conclusion: The Tribunal dismissed the appeals filed by the Revenue, confirming the order of the CIT(A) that the reassessments for the assessment years 1992-93 and 1993-94 were invalid as they were initiated beyond the permissible period of four years and there was no failure on the part of the assessee to disclose material facts fully and truly. Consequently, the cross-objections filed by the assessee were dismissed as not pressed.
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