https://www.taxtmi.com/caselaws?id=781936 Reassessment under section 147 was held invalid where a non-resident company's only Indian income was interest subject to tax deduction at source and section 115A(5) relieved it from filing a return. Non-filing of a return, by itself, could not justify reopening in the absence of material showing escapement of income. The record also did not support the assessed figure, which was found to be double the actual interest, and no basis for that amount was shown. On these facts, the statutory foundation for invoking section 147 failed, and the reopening was quashed in favour of the assessee. en-us Wed, 19 Nov 2025 00:00:00 +0530 Sat, 22 Nov 2025 07:36:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781936 Reassessment under section 147 was held invalid where a non-resident company's only Indian income was interest subject to tax deduction at source and section 115A(5) relieved it from filing a return. Non-filing of a return, by itself, could not justify reopening in the absence of material showing escapement of income. The record also did not support the assessed figure, which was found to be double the actual interest, and no basis for that amount was shown. On these facts, the statutory foundation for invoking section 147 failed, and the reopening was quashed in favour of the assessee. Case-Laws Income Tax Wed, 19 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781936