https://www.taxtmi.com/caselaws?id=461532 ITAT Amritsar held that reopening assessment u/s 147 was invalid as the assessee had disclosed all material facts regarding External Development Charges and license fees in balance sheets, with no tangible material suggesting non-disclosure. The AO's reasons were based on existing assessment records rather than new information. Additionally, ITAT ruled that EDC and license fees collected by the assessee as collecting agent for State Government should be treated as capital receipts, not revenue receipts, since the assessee had no control over charge fixation or fund utilization. Both additions were deleted in favor of the assessee. en-us Thu, 30 May 2024 00:00:00 +0530 Fri, 11 Apr 2025 18:56:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461532 ITAT Amritsar held that reopening assessment u/s 147 was invalid as the assessee had disclosed all material facts regarding External Development Charges and license fees in balance sheets, with no tangible material suggesting non-disclosure. The AO's reasons were based on existing assessment records rather than new information. Additionally, ITAT ruled that EDC and license fees collected by the assessee as collecting agent for State Government should be treated as capital receipts, not revenue receipts, since the assessee had no control over charge fixation or fund utilization. Both additions were deleted in favor of the assessee. Case-Laws Income Tax Thu, 30 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461532