https://www.taxtmi.com/caselaws?id=774458 HC quashed reassessment proceedings under Section 148 for AY 2003-04 involving non-compete fee of Rs. 10 crores. Revenue department attempted to reopen assessment alleging non-disclosure of material facts regarding capital vs revenue nature of expenditure. Court held that since assessee had disclosed all relevant agreements during original assessment and AO had already scrutinized documents treating expenditure as revenue, reopening based on same materials was impermissible. No correlation existed between Rs. 10 crores expense and Rs. 15 crores income in different assessment years. Reassessment proceedings quashed favoring assessee. en-us Wed, 25 Jun 2025 00:00:00 +0530 Tue, 10 Mar 2026 15:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774458 HC quashed reassessment proceedings under Section 148 for AY 2003-04 involving non-compete fee of Rs. 10 crores. Revenue department attempted to reopen assessment alleging non-disclosure of material facts regarding capital vs revenue nature of expenditure. Court held that since assessee had disclosed all relevant agreements during original assessment and AO had already scrutinized documents treating expenditure as revenue, reopening based on same materials was impermissible. No correlation existed between Rs. 10 crores expense and Rs. 15 crores income in different assessment years. Reassessment proceedings quashed favoring assessee. Case-Laws Income Tax Wed, 25 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774458