https://www.taxtmi.com/caselaws?id=344014 The Tribunal held that the reopening of the assessment under Section 147 of the Income Tax Act beyond four years was invalid as it was based on a mere change of opinion without new material, and the assessee had fully disclosed all necessary facts during the original assessment. Additionally, the disallowance under Section 40(a)(ia) was not justified as the TDS was deposited before the return due date. The Tribunal allowed the assessee's appeal and dismissed the Revenue's appeal, affirming the deletion of the disallowance and invalidating the assessment reopening. en-us Fri, 26 May 2017 00:00:00 +0530 Wed, 07 Jun 2017 06:27:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=344014 The Tribunal held that the reopening of the assessment under Section 147 of the Income Tax Act beyond four years was invalid as it was based on a mere change of opinion without new material, and the assessee had fully disclosed all necessary facts during the original assessment. Additionally, the disallowance under Section 40(a)(ia) was not justified as the TDS was deposited before the return due date. The Tribunal allowed the assessee's appeal and dismissed the Revenue's appeal, affirming the deletion of the disallowance and invalidating the assessment reopening. Case-Laws Income Tax Fri, 26 May 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=344014