https://www.taxtmi.com/caselaws?id=457129 A reassessment initiation under section 148A(d) cannot be sustained where the assessee's material objections have not been duly considered, including contentions that the receipts were not royalty or fees for technical services and that the India-US DTAA and tax residency certificate were relevant. The Delhi HC found that the replies required meaningful examination and, since the respondents did not oppose fresh consideration, set aside the 148A(d) orders and the consequential section 148 notices. The matters were remanded for fresh adjudication after considering the petitioners' replies and directed to proceed in accordance with law. en-us Thu, 17 Nov 2022 00:00:00 +0530 Fri, 06 Sep 2024 20:52:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=457129 A reassessment initiation under section 148A(d) cannot be sustained where the assessee's material objections have not been duly considered, including contentions that the receipts were not royalty or fees for technical services and that the India-US DTAA and tax residency certificate were relevant. The Delhi HC found that the replies required meaningful examination and, since the respondents did not oppose fresh consideration, set aside the 148A(d) orders and the consequential section 148 notices. The matters were remanded for fresh adjudication after considering the petitioners' replies and directed to proceed in accordance with law. Case-Laws Income Tax Thu, 17 Nov 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=457129