https://www.taxtmi.com/caselaws?id=411967 Reassessment under Sections 147 and 148 was initiated within four years on the basis of tangible material indicating possible escapement of income, so the decisive question was whether there was reason to believe rather than a mere change of opinion. The Court accepted that the recorded reasons showed fresh material concerning deduction of loan guarantee fee paid to a foreign group company without tax deduction at source, and held that the reopening was not barred at the threshold. The assessee's disclosure of facts did not prevent reassessment, and the merits of the disallowance were left to be examined in the reassessment proceedings. The challenge to the notice and the order disposing of objections was rejected. en-us Wed, 01 Sep 2021 00:00:00 +0530 Fri, 24 Dec 2021 17:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=411967 Reassessment under Sections 147 and 148 was initiated within four years on the basis of tangible material indicating possible escapement of income, so the decisive question was whether there was reason to believe rather than a mere change of opinion. The Court accepted that the recorded reasons showed fresh material concerning deduction of loan guarantee fee paid to a foreign group company without tax deduction at source, and held that the reopening was not barred at the threshold. The assessee's disclosure of facts did not prevent reassessment, and the merits of the disallowance were left to be examined in the reassessment proceedings. The challenge to the notice and the order disposing of objections was rejected. Case-Laws Income Tax Wed, 01 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=411967