https://www.taxtmi.com/caselaws?id=352302 Reassessment under section 147 was held invalid because the reopening rested only on material already disclosed in the return, computation and audit report, with no fresh tangible material to create a live nexus with a bona fide belief that income had escaped assessment. The recorded reasons merely reappraised earlier facts, including the taxpayer's note that IT support service receipts were not royalty or fees for technical services under the treaty. Since the jurisdictional condition of objective material was not satisfied, the reopening lacked legal foundation and was quashed in favour of the assessee. en-us Fri, 10 Nov 2017 00:00:00 +0530 Tue, 12 Dec 2017 09:35:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=352302 Reassessment under section 147 was held invalid because the reopening rested only on material already disclosed in the return, computation and audit report, with no fresh tangible material to create a live nexus with a bona fide belief that income had escaped assessment. The recorded reasons merely reappraised earlier facts, including the taxpayer's note that IT support service receipts were not royalty or fees for technical services under the treaty. Since the jurisdictional condition of objective material was not satisfied, the reopening lacked legal foundation and was quashed in favour of the assessee. Case-Laws Income Tax Fri, 10 Nov 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=352302