https://www.taxtmi.com/caselaws?id=386590 The ITAT dismissed the Revenue's appeal, upholding the Ld. CIT(A)'s order quashing the reassessment proceedings under sections 147/148 of the Income Tax Act, 1961. The ITAT held that the reassessment was based on a mere change of opinion without any new material facts and that the franchise fee paid by the assessee should be treated as revenue expenditure. The ITAT emphasized the statutory protection under the proviso to section 147, which prevents reassessment after four years unless there is a failure to disclose material facts fully and truly. en-us Wed, 31 Jul 2019 00:00:00 +0530 Thu, 03 Oct 2019 07:54:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=386590 The ITAT dismissed the Revenue's appeal, upholding the Ld. CIT(A)'s order quashing the reassessment proceedings under sections 147/148 of the Income Tax Act, 1961. The ITAT held that the reassessment was based on a mere change of opinion without any new material facts and that the franchise fee paid by the assessee should be treated as revenue expenditure. The ITAT emphasized the statutory protection under the proviso to section 147, which prevents reassessment after four years unless there is a failure to disclose material facts fully and truly. Case-Laws Income Tax Wed, 31 Jul 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=386590