https://www.taxtmi.com/caselaws?id=777322 Reassessment under section 147 was invalid where it was initiated solely on the alleged taxability of management charges as fees for technical services under the India-UK DTAA, and the very addition made on that basis was later deleted in appeal. Once the income that triggered the reopening was held not taxable and that deletion attained finality, the jurisdictional foundation for reassessment disappeared. The reassessment order was therefore quashed in favour of the assessee. en-us Mon, 25 Aug 2025 00:00:00 +0530 Thu, 28 Aug 2025 08:32:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777322 Reassessment under section 147 was invalid where it was initiated solely on the alleged taxability of management charges as fees for technical services under the India-UK DTAA, and the very addition made on that basis was later deleted in appeal. Once the income that triggered the reopening was held not taxable and that deletion attained finality, the jurisdictional foundation for reassessment disappeared. The reassessment order was therefore quashed in favour of the assessee. Case-Laws Income Tax Mon, 25 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777322