https://www.taxtmi.com/caselaws?id=428929 Reassessment under section 147 was upheld because the original assessment had not examined the specific TDS issue, so reopening within four years was not barred by change of opinion. The payment to IFANCA for halal supervision and certification was held not to be "included services" or technical services, as the process did not make available technical knowledge, experience, skill, or know-how to the assessee; accordingly, no tax deduction at source was required and the disallowance under section 40(a)(ia) was deleted. en-us Wed, 12 Oct 2022 00:00:00 +0530 Fri, 14 Oct 2022 08:48:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=428929 Reassessment under section 147 was upheld because the original assessment had not examined the specific TDS issue, so reopening within four years was not barred by change of opinion. The payment to IFANCA for halal supervision and certification was held not to be "included services" or technical services, as the process did not make available technical knowledge, experience, skill, or know-how to the assessee; accordingly, no tax deduction at source was required and the disallowance under section 40(a)(ia) was deleted. Case-Laws Income Tax Wed, 12 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=428929