https://www.taxtmi.com/caselaws?id=272008 Reassessment under Section 147 could not be sustained where the assessee had disclosed all primary facts concerning royalty income and interest on delayed royalty, including agreements, returns, audit materials and transfer pricing documentation. The Revenue's reasons sought only to re-characterise the disclosed material and draw fresh legal inferences, without any new primary fact or failure to disclose fully and truly all material facts. The reopening was therefore treated as a mere change of opinion, which is impermissible, and the notice under Section 148 and the order rejecting objections were set aside. en-us Thu, 18 Feb 2016 00:00:00 +0530 Fri, 13 May 2016 15:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=272008 Reassessment under Section 147 could not be sustained where the assessee had disclosed all primary facts concerning royalty income and interest on delayed royalty, including agreements, returns, audit materials and transfer pricing documentation. The Revenue's reasons sought only to re-characterise the disclosed material and draw fresh legal inferences, without any new primary fact or failure to disclose fully and truly all material facts. The reopening was therefore treated as a mere change of opinion, which is impermissible, and the notice under Section 148 and the order rejecting objections were set aside. Case-Laws Income Tax Thu, 18 Feb 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=272008