https://www.taxtmi.com/caselaws?id=180486 The Tribunal upheld the challenge to the validity of reassessment under section 147 read with section 148 of the Income Tax Act, 1961. It was found that the notice for reassessment was validly issued, but as the reassessment was based on a change of opinion without new material, it was deemed unsustainable. Additionally, the treatment of technical know-how fees as capital in nature was overturned, with the reassessment declared null and void due to lack of fresh material, leading to the appeal being allowed. en-us Wed, 24 Aug 2011 00:00:00 +0530 Sat, 26 Mar 2016 11:06:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=180486 The Tribunal upheld the challenge to the validity of reassessment under section 147 read with section 148 of the Income Tax Act, 1961. It was found that the notice for reassessment was validly issued, but as the reassessment was based on a change of opinion without new material, it was deemed unsustainable. Additionally, the treatment of technical know-how fees as capital in nature was overturned, with the reassessment declared null and void due to lack of fresh material, leading to the appeal being allowed. Case-Laws Income Tax Wed, 24 Aug 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=180486