https://www.taxtmi.com/caselaws?id=398340 The Tribunal dismissed the revenue's appeal, affirming the CIT(A)'s decision to quash the reassessment order under Section 147 of the Income Tax Act, 1961, as it was based on a mere change of opinion without new tangible material. Furthermore, the disallowance under Section 40(a)(i) was deemed unjustified, as payments to foreign companies did not attract Section 195 provisions. The Tribunal underscored the necessity for tangible material in reopening assessments and cautioned against using reassessment as a means to review previously accepted positions. en-us Wed, 09 Sep 2020 00:00:00 +0530 Fri, 08 Nov 2024 12:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=398340 The Tribunal dismissed the revenue's appeal, affirming the CIT(A)'s decision to quash the reassessment order under Section 147 of the Income Tax Act, 1961, as it was based on a mere change of opinion without new tangible material. Furthermore, the disallowance under Section 40(a)(i) was deemed unjustified, as payments to foreign companies did not attract Section 195 provisions. The Tribunal underscored the necessity for tangible material in reopening assessments and cautioned against using reassessment as a means to review previously accepted positions. Case-Laws Income Tax Wed, 09 Sep 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=398340