https://www.taxtmi.com/caselaws?id=330941 Reassessment beyond four years is not sustainable where the original scrutiny assessment had already examined the issue and the recorded reasons do not allege failure to fully and truly disclose material facts; reopening on the same material is a mere change of opinion. A licence fee paid for obtaining catering rights is treated as a commercial payment, not fees for managerial, technical or consultancy services, so no TDS was required under the stated provisions and the related disallowance did not survive. A genuine embezzlement loss is allowable when it crystallises on commercial facts, and unsupported ad hoc disallowances, exceptional cash payments, burning expenses and unexplained expenditure additions were deleted. en-us Fri, 29 Jul 2016 00:00:00 +0530 Tue, 09 Aug 2016 12:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=330941 Reassessment beyond four years is not sustainable where the original scrutiny assessment had already examined the issue and the recorded reasons do not allege failure to fully and truly disclose material facts; reopening on the same material is a mere change of opinion. A licence fee paid for obtaining catering rights is treated as a commercial payment, not fees for managerial, technical or consultancy services, so no TDS was required under the stated provisions and the related disallowance did not survive. A genuine embezzlement loss is allowable when it crystallises on commercial facts, and unsupported ad hoc disallowances, exceptional cash payments, burning expenses and unexplained expenditure additions were deleted. Case-Laws Income Tax Fri, 29 Jul 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=330941