https://www.taxtmi.com/caselaws?id=423183 Reassessment was invalid because the recorded reasons did not identify the precise Chapter XVII provision allegedly requiring tax deduction at source and did not establish, on their face, any statutory basis for disallowing transport payments. The reopening had to stand or fall on the reasons recorded at initiation, and it could not be supported later by external material or subsequent explanation. As the foundation for reassessment was held defective, the reassessments could not survive, and the consequential revision under section 263, being dependent on those proceedings, also failed. en-us Thu, 12 May 2022 00:00:00 +0530 Wed, 01 Jun 2022 07:43:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=423183 Reassessment was invalid because the recorded reasons did not identify the precise Chapter XVII provision allegedly requiring tax deduction at source and did not establish, on their face, any statutory basis for disallowing transport payments. The reopening had to stand or fall on the reasons recorded at initiation, and it could not be supported later by external material or subsequent explanation. As the foundation for reassessment was held defective, the reassessments could not survive, and the consequential revision under section 263, being dependent on those proceedings, also failed. Case-Laws Income Tax Thu, 12 May 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=423183