https://www.taxtmi.com/caselaws?id=767262 The ITAT Lucknow ruled in favor of the assessee on two key issues. First, the tribunal quashed reassessment proceedings for five years, holding that reopening under section 147 was invalid as it was based on a change of opinion rather than new tangible material. The AO had access to relevant disclosures during original assessment but initially rejected audit objections, only accepting them after intervention from PCIT office. Second, regarding income accrual, the tribunal upheld CIT(A)'s decision that the assessee was merely a contract manufacturer for UBL, entitled only to reimbursement of expenses and bottling charges, with UBL being the actual income earner from liquor sales. en-us Fri, 28 Feb 2025 00:00:00 +0530 Thu, 13 Mar 2025 08:35:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767262 The ITAT Lucknow ruled in favor of the assessee on two key issues. First, the tribunal quashed reassessment proceedings for five years, holding that reopening under section 147 was invalid as it was based on a change of opinion rather than new tangible material. The AO had access to relevant disclosures during original assessment but initially rejected audit objections, only accepting them after intervention from PCIT office. Second, regarding income accrual, the tribunal upheld CIT(A)'s decision that the assessee was merely a contract manufacturer for UBL, entitled only to reimbursement of expenses and bottling charges, with UBL being the actual income earner from liquor sales. Case-Laws Income Tax Fri, 28 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767262