https://www.taxtmi.com/highlights?id=75876 Validity of Reopening of assessment - tangible materials - petitioner had failed to deduct withholding tax on the assumption that the AAR would issue a favourable ruling - The High court observed that the reassessment proceedings were initiated on a factual error regarding the scope of transactions covered by the AAR application. It held that if reassessment proceedings are initiated mechanically or on a wrong factual basis, they may warrant interference. - Regarding the approval for reassessment, the court found that the Chief Commissioner of Income Tax was not a specified authority u/s 151 for the relevant assessment years, rendering the reassessment proceedings invalid. - Consequently, the court quashed the impugned orders and notices, rendering the assessment orders null and void. en-us Wed, 20 Mar 2024 09:19:42 +0530 Wed, 20 Mar 2024 09:19:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=75876 Validity of Reopening of assessment - tangible materials - petitioner had failed to deduct withholding tax on the assumption that the AAR would issue a favourable ruling - The High court observed that the reassessment proceedings were initiated on a factual error regarding the scope of transactions covered by the AAR application. It held that if reassessment proceedings are initiated mechanically or on a wrong factual basis, they may warrant interference. - Regarding the approval for reassessment, the court found that the Chief Commissioner of Income Tax was not a specified authority u/s 151 for the relevant assessment years, rendering the reassessment proceedings invalid. - Consequently, the court quashed the impugned orders and notices, rendering the assessment orders null and void. Highlights Income Tax Wed, 20 Mar 2024 09:19:42 +0530 https://www.taxtmi.com/highlights?id=75876