https://www.taxtmi.com/caselaws?id=333031 Reopening of assessment challenged where AO disallowed expenditure under tax deduction rules for late TDS deposit. Court found the AO did not address the assessee's specific objection that foreign commission payments had no Indian nexus and that foreign agents lacked any Indian establishment, making the requirement to deduct TDS doubtful; AO also left the assessee's foreign commission claim intact. On the question of change of opinion, the HC concluded the reassessment notice could not be sustained and set it aside. Petition allowed and assessment reopening annulled on these grounds. en-us Tue, 27 Sep 2016 00:00:00 +0530 Thu, 05 Feb 2026 16:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=333031 Reopening of assessment challenged where AO disallowed expenditure under tax deduction rules for late TDS deposit. Court found the AO did not address the assessee's specific objection that foreign commission payments had no Indian nexus and that foreign agents lacked any Indian establishment, making the requirement to deduct TDS doubtful; AO also left the assessee's foreign commission claim intact. On the question of change of opinion, the HC concluded the reassessment notice could not be sustained and set it aside. Petition allowed and assessment reopening annulled on these grounds. Case-Laws Income Tax Tue, 27 Sep 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=333031