https://www.taxtmi.com/caselaws?id=788663 A reassessment under the Income-tax Act, 1961 was held impermissible where the original scrutiny assessment under Section 143(3) had already examined the relevant payment and TDS issue, and the Revenue could not show any failure by the assessee to disclose fully and truly all material facts. Mere reconsideration of an issue already dealt with in the concluded assessment could not satisfy the conditions for reopening under Section 147. The court also noted that the payments were not claimed as expenditure in a manner attracting disallowance under Section 40(a)(ia). The reassessment notice and consequent proceedings were therefore invalid. en-us Thu, 05 Mar 2026 00:00:00 +0530 Thu, 26 Mar 2026 09:05:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788663 A reassessment under the Income-tax Act, 1961 was held impermissible where the original scrutiny assessment under Section 143(3) had already examined the relevant payment and TDS issue, and the Revenue could not show any failure by the assessee to disclose fully and truly all material facts. Mere reconsideration of an issue already dealt with in the concluded assessment could not satisfy the conditions for reopening under Section 147. The court also noted that the payments were not claimed as expenditure in a manner attracting disallowance under Section 40(a)(ia). The reassessment notice and consequent proceedings were therefore invalid. Case-Laws Income Tax Thu, 05 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788663