https://www.taxtmi.com/caselaws?id=386317 The HC dismissed the Revenue's appeal, affirming the ITAT's decision that the reassessment under Section 147 was invalid. The court agreed that the reassessment was based on a mere change of opinion, as the original assessment had already considered the Technical Know-How Fee. The substantial question of law was resolved in favor of the Assessee, confirming that mere change of opinion does not justify reassessment. en-us Fri, 06 Sep 2019 00:00:00 +0530 Fri, 08 Nov 2024 12:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=386317 The HC dismissed the Revenue's appeal, affirming the ITAT's decision that the reassessment under Section 147 was invalid. The court agreed that the reassessment was based on a mere change of opinion, as the original assessment had already considered the Technical Know-How Fee. The substantial question of law was resolved in favor of the Assessee, confirming that mere change of opinion does not justify reassessment. Case-Laws Income Tax Fri, 06 Sep 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=386317