https://www.taxtmi.com/caselaws?id=351078 The Tribunal upheld the Commissioner (Appeals)' decision that the re-opening of assessment under section 147 of the Act was invalid due to being based on a mere change of opinion after the limitation period, without failure to disclose necessary facts. Additionally, the disallowance of bonus and commission paid to directors under section 40A(2)(b) of the Act was deemed impermissible as it resulted from a change of opinion and was initiated beyond the limitation period without any failure to disclose material facts. Consequently, the Tribunal dismissed the Revenue's appeal, affirming the Commissioner (Appeals)' decision. en-us Thu, 09 Nov 2017 00:00:00 +0530 Sat, 18 Nov 2017 14:08:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=351078 The Tribunal upheld the Commissioner (Appeals)' decision that the re-opening of assessment under section 147 of the Act was invalid due to being based on a mere change of opinion after the limitation period, without failure to disclose necessary facts. Additionally, the disallowance of bonus and commission paid to directors under section 40A(2)(b) of the Act was deemed impermissible as it resulted from a change of opinion and was initiated beyond the limitation period without any failure to disclose material facts. Consequently, the Tribunal dismissed the Revenue's appeal, affirming the Commissioner (Appeals)' decision. Case-Laws Income Tax Thu, 09 Nov 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=351078