https://www.taxtmi.com/caselaws?id=761900 In a limited remand, the Assessing Officer was bound to confine the enquiry to the royalty issue identified by the appellate directions and could not broaden the assessment to treat the same receipts as fees for technical services. The Tribunal held that the remand was not an open remand and did not authorise a fresh examination of a different head of income. By travelling beyond the scope of the remand and introducing a new basis of taxation not carried in appeal, the Assessing Officer acted without jurisdiction. The addition was therefore deleted, and the assessee succeeded on the jurisdictional objection. en-us Tue, 08 Oct 2024 00:00:00 +0530 Tue, 19 Nov 2024 11:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761900 In a limited remand, the Assessing Officer was bound to confine the enquiry to the royalty issue identified by the appellate directions and could not broaden the assessment to treat the same receipts as fees for technical services. The Tribunal held that the remand was not an open remand and did not authorise a fresh examination of a different head of income. By travelling beyond the scope of the remand and introducing a new basis of taxation not carried in appeal, the Assessing Officer acted without jurisdiction. The addition was therefore deleted, and the assessee succeeded on the jurisdictional objection. Case-Laws Income Tax Tue, 08 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761900