https://www.taxtmi.com/caselaws?id=468687 Reassessment under section 147 fails where the recorded reasons for reopening do not survive: for the first two years, the Assessing Officer accepted that returns had been filed and that licence fee income was business income, so additions on other issues could not be sustained and the reopening was deleted. Reassessment is valid where fresh and tangible material creates a live belief of escapement of income: for the later year, material from a subsequent assessment supported reopening. On merits, expense disallowances were partly retained, while the assessees' reduced offer for administrative and other expenses was accepted as reasonable in the later years. en-us Thu, 06 Feb 2025 00:00:00 +0530 Sun, 17 May 2026 09:19:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468687 Reassessment under section 147 fails where the recorded reasons for reopening do not survive: for the first two years, the Assessing Officer accepted that returns had been filed and that licence fee income was business income, so additions on other issues could not be sustained and the reopening was deleted. Reassessment is valid where fresh and tangible material creates a live belief of escapement of income: for the later year, material from a subsequent assessment supported reopening. On merits, expense disallowances were partly retained, while the assessees' reduced offer for administrative and other expenses was accepted as reasonable in the later years. Case-Laws Income Tax Thu, 06 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468687