https://www.taxtmi.com/caselaws?id=763503 ITAT Bangalore quashed reassessment proceedings under section 147 where notice was issued beyond four years. The tribunal held that for reopening assessment after four years, the assessing officer must specifically allege failure by assessee to disclose material facts, which was absent in the recorded reasons. Merely stating that non-deduction of tax at source on payments to non-residents was a wilful act to reduce taxable income does not constitute allegation of non-disclosure. The tribunal distinguished between matters settled under VSV 2020 (relating to resident payments) and current reopening issue (non-resident payments), finding them to be different issues. Appeal decided in favor of assessee. en-us Fri, 13 Dec 2024 00:00:00 +0530 Fri, 20 Dec 2024 08:48:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763503 ITAT Bangalore quashed reassessment proceedings under section 147 where notice was issued beyond four years. The tribunal held that for reopening assessment after four years, the assessing officer must specifically allege failure by assessee to disclose material facts, which was absent in the recorded reasons. Merely stating that non-deduction of tax at source on payments to non-residents was a wilful act to reduce taxable income does not constitute allegation of non-disclosure. The tribunal distinguished between matters settled under VSV 2020 (relating to resident payments) and current reopening issue (non-resident payments), finding them to be different issues. Appeal decided in favor of assessee. Case-Laws Income Tax Fri, 13 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763503