https://www.taxtmi.com/caselaws?id=184330 Reassessment under sections 147 and 148 was treated as valid where fresh material suggesting escapement of income came to the Assessing Officer's notice, and the reopening was not merely a change of opinion on facts already examined. The article also explains that section 40(a)(ia) disallows contractor-related expenditure, including labour supply payments, when tax deductible under section 194C is not deducted or paid within the prescribed time. The characterisation of the recipients as employees was held irrelevant once the payments were found to be contract-based, and oral or implied contracts were also treated as within section 194C. The reassessment challenge and the TDS-based disallowance were both upheld. en-us Thu, 28 Aug 2014 00:00:00 +0530 Wed, 06 Jul 2016 10:00:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=184330 Reassessment under sections 147 and 148 was treated as valid where fresh material suggesting escapement of income came to the Assessing Officer's notice, and the reopening was not merely a change of opinion on facts already examined. The article also explains that section 40(a)(ia) disallows contractor-related expenditure, including labour supply payments, when tax deductible under section 194C is not deducted or paid within the prescribed time. The characterisation of the recipients as employees was held irrelevant once the payments were found to be contract-based, and oral or implied contracts were also treated as within section 194C. The reassessment challenge and the TDS-based disallowance were both upheld. Case-Laws Income Tax Thu, 28 Aug 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=184330