https://www.taxtmi.com/caselaws?id=775864 The ITAT Delhi held that the reopening of the assessment beyond the six-year limitation period was invalid as the assessee had disclosed all relevant facts in the original return. The issue regarding TDS on External Development Charges was judicially settled in favor of the revenue after the original assessment under section 143(3) was completed. The circular relied upon by the AO for reopening lacked retrospective effect and could not override judicial interpretation or bind the AO retrospectively. Consequently, the reopening under section 147 was held to be an illegal exercise of jurisdiction, being barred by the proviso to section 147. The appeal of the assessee was allowed. en-us Wed, 30 Jul 2025 00:00:00 +0530 Fri, 01 Aug 2025 08:15:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775864 The ITAT Delhi held that the reopening of the assessment beyond the six-year limitation period was invalid as the assessee had disclosed all relevant facts in the original return. The issue regarding TDS on External Development Charges was judicially settled in favor of the revenue after the original assessment under section 143(3) was completed. The circular relied upon by the AO for reopening lacked retrospective effect and could not override judicial interpretation or bind the AO retrospectively. Consequently, the reopening under section 147 was held to be an illegal exercise of jurisdiction, being barred by the proviso to section 147. The appeal of the assessee was allowed. Case-Laws Income Tax Wed, 30 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775864