https://www.taxtmi.com/caselaws?id=767205 Reassessment beyond four years is invalid where it rests on the same material already on record and no failure to make full and true disclosure of material facts is shown; on that basis, the reopening notice and consequential reassessment were quashed. UK film tax relief already embedded in the receipt chain could not be taxed again as a separate income item, so the addition was deleted. Payments to Winford Production Ltd. for film-production reimbursements, including local arrangements and logistics, did not make available technical knowledge, skill, know-how, or process; they were not fees for technical services, and no withholding disallowance could survive. The Revenue's appeal failed and the assessee's cross-objection succeeded. en-us Fri, 21 Feb 2025 00:00:00 +0530 Sat, 11 Oct 2025 13:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767205 Reassessment beyond four years is invalid where it rests on the same material already on record and no failure to make full and true disclosure of material facts is shown; on that basis, the reopening notice and consequential reassessment were quashed. UK film tax relief already embedded in the receipt chain could not be taxed again as a separate income item, so the addition was deleted. Payments to Winford Production Ltd. for film-production reimbursements, including local arrangements and logistics, did not make available technical knowledge, skill, know-how, or process; they were not fees for technical services, and no withholding disallowance could survive. The Revenue's appeal failed and the assessee's cross-objection succeeded. Case-Laws Income Tax Fri, 21 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767205