https://www.taxtmi.com/caselaws?id=751423 Karnataka HC held that reopening of assessment beyond four years was barred in law. The case involved disallowance under Section 40(a)(ia) for non-deduction of TDS on stake money paid to horse owners under Sections 194B/194BB. The court found that the assessing officer had already examined the TDS deduction issue during original scrutiny assessment while considering the disallowance. Since the petitioner had disclosed all primary facts in financial statements without claiming any expenditure, there was no failure to disclose material facts. The revenue's reasons for reassessment were recorded arbitrarily without considering all circumstances. Assessment reopening was therefore invalid. en-us Mon, 25 Mar 2024 00:00:00 +0530 Mon, 15 Apr 2024 10:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751423 Karnataka HC held that reopening of assessment beyond four years was barred in law. The case involved disallowance under Section 40(a)(ia) for non-deduction of TDS on stake money paid to horse owners under Sections 194B/194BB. The court found that the assessing officer had already examined the TDS deduction issue during original scrutiny assessment while considering the disallowance. Since the petitioner had disclosed all primary facts in financial statements without claiming any expenditure, there was no failure to disclose material facts. The revenue's reasons for reassessment were recorded arbitrarily without considering all circumstances. Assessment reopening was therefore invalid. Case-Laws Income Tax Mon, 25 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751423