https://www.taxtmi.com/caselaws?id=206722 HC quashed reassessment notices issued u/s 147/148 for AYs 2006-07 and 2007-08, holding that the Assessing Officer's reasons constituted a mere change of opinion. The AO's view that domain registry activities did not constitute IT enabled services involving value addition had already been considered and reversed in appellate proceedings, and no new tangible material was shown. Reliance on observations in the AY 2008-09 assessment, where no claim u/s 10A was made, was held to be a contrived basis to reopen earlier years. HC emphasised the need for consistency in a multi-year deduction u/s 10A and set aside the impugned notices. en-us Thu, 29 Sep 2011 00:00:00 +0530 Tue, 02 Dec 2025 20:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=206722 HC quashed reassessment notices issued u/s 147/148 for AYs 2006-07 and 2007-08, holding that the Assessing Officer's reasons constituted a mere change of opinion. The AO's view that domain registry activities did not constitute IT enabled services involving value addition had already been considered and reversed in appellate proceedings, and no new tangible material was shown. Reliance on observations in the AY 2008-09 assessment, where no claim u/s 10A was made, was held to be a contrived basis to reopen earlier years. HC emphasised the need for consistency in a multi-year deduction u/s 10A and set aside the impugned notices. Case-Laws Income Tax Thu, 29 Sep 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=206722