https://www.taxtmi.com/caselaws?id=263334 The ITAT dismissed both appeals by the Revenue. The reassessment under section 147 was deemed invalid due to a mere change of opinion, as the issue had already been scrutinized during the original assessment. The deletion of penalty under section 271(1)(c) was upheld, as the addition made for commission payments was found invalid by the ITAT previously. The ITAT emphasized adherence to legal principles and precedents in similar cases, affirming the decisions of the Learned CIT(Appeals) in both matters. en-us Wed, 25 Feb 2015 00:00:00 +0530 Mon, 27 Jul 2015 16:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=263334 The ITAT dismissed both appeals by the Revenue. The reassessment under section 147 was deemed invalid due to a mere change of opinion, as the issue had already been scrutinized during the original assessment. The deletion of penalty under section 271(1)(c) was upheld, as the addition made for commission payments was found invalid by the ITAT previously. The ITAT emphasized adherence to legal principles and precedents in similar cases, affirming the decisions of the Learned CIT(Appeals) in both matters. Case-Laws Income Tax Wed, 25 Feb 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=263334