https://www.taxtmi.com/caselaws?id=70692 The Tribunal upheld the reopening of assessment under section 147 of the IT Act, emphasizing the non-disclosure of material facts justifying reassessment. Regarding the disallowance of interest under section 40(a), the Tribunal ruled in favor of the assessee, stating that if interest is exempt under section 10(15)(iv)(f), no disallowance should be made under section 40(a). Compliance with section 10(15)(iv)(f) exempts interest from disallowance under section 40(a)(i). The Tribunal remitted the issue of TDS deduction for royalty and fees under the DTAA between India and Korea back to the AO for further examination. en-us Fri, 19 Dec 2008 00:00:00 +0530 Thu, 13 Jun 2013 12:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=70692 The Tribunal upheld the reopening of assessment under section 147 of the IT Act, emphasizing the non-disclosure of material facts justifying reassessment. Regarding the disallowance of interest under section 40(a), the Tribunal ruled in favor of the assessee, stating that if interest is exempt under section 10(15)(iv)(f), no disallowance should be made under section 40(a). Compliance with section 10(15)(iv)(f) exempts interest from disallowance under section 40(a)(i). The Tribunal remitted the issue of TDS deduction for royalty and fees under the DTAA between India and Korea back to the AO for further examination. Case-Laws Income Tax Fri, 19 Dec 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=70692