https://www.taxtmi.com/caselaws?id=185402 The Tribunal upheld the validity of the assessment reopening for AY 2004-05 as no initial opinion was formed under section 143(1). Receipts from second leg contracts were deemed taxable under section 44BB, not as royalty under section 9(1)(vi), following precedent. Interest under section 234B was ruled not chargeable due to the entire income being subject to TDS under section 195. The appeals by the Revenue were dismissed, while the Assessee's appeals were allowed for AY 2007-08 and 2008-09 but dismissed for AY 2004-05 on the reopening issue. en-us Sun, 07 Feb 2016 00:00:00 +0530 Thu, 11 Aug 2016 15:27:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=185402 The Tribunal upheld the validity of the assessment reopening for AY 2004-05 as no initial opinion was formed under section 143(1). Receipts from second leg contracts were deemed taxable under section 44BB, not as royalty under section 9(1)(vi), following precedent. Interest under section 234B was ruled not chargeable due to the entire income being subject to TDS under section 195. The appeals by the Revenue were dismissed, while the Assessee's appeals were allowed for AY 2007-08 and 2008-09 but dismissed for AY 2004-05 on the reopening issue. Case-Laws Income Tax Sun, 07 Feb 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=185402