Assessment Reopening Dispute: Section 147 Challenge on Directors' Remuneration Disallowance Lacks New Material, Assessee Claims Inconsistency.

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....Reopening of assessment u/s 147 - disallowance u/s 36(i)(ii) for directors remuneration - Assessee argued absence of any fresh material in the possession of the AO and that too after the expiry of four years - As an assessing officer, the respondent cannot take a different view for the assessment year 2007-2008 from the view is taken for the assessment year 2008-2009 by the Commissioner of Income Tax (Appeals) - HC....