https://www.taxtmi.com/caselaws?id=789500 Reopening under Section 147 was treated as permissible where the return had only been processed under Section 143(1) and no scrutiny assessment had been made; the jurisdictional challenge therefore failed. On fees for technical services, receipts for freight, hire charges, meals, accommodation and travel were held not to constitute technical services, and mere identification of third parties or facilitation of mobilization and demobilization did not satisfy the India-Netherlands DTAA make-available test. Reimbursable expenditure was accepted only for freight, travel, accommodation and meals on the material shown, while the broader reimbursement claim was not fully established on record. en-us Tue, 27 Jan 2026 00:00:00 +0530 Thu, 09 Apr 2026 08:09:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789500 Reopening under Section 147 was treated as permissible where the return had only been processed under Section 143(1) and no scrutiny assessment had been made; the jurisdictional challenge therefore failed. On fees for technical services, receipts for freight, hire charges, meals, accommodation and travel were held not to constitute technical services, and mere identification of third parties or facilitation of mobilization and demobilization did not satisfy the India-Netherlands DTAA make-available test. Reimbursable expenditure was accepted only for freight, travel, accommodation and meals on the material shown, while the broader reimbursement claim was not fully established on record. Case-Laws Income Tax Tue, 27 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789500