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2017 (8) TMI 1346 - AT - Income TaxReopening of assessment - Held that:- Assessing Officer had no tangible material to justify his “reason to believe” that income has escaped assessment. The reassessment proceedings initiated by the Assessing Officer u/s.147 are without jurisdiction and hence, are not sustainable. See case of Sandvik Information Technology AB (a group of Company of assessee [2016 (12) TMI 1663 - ITAT PUNE] Whether IT support services is royalty or FTS - Held that:- This issue has been decided by the Pune Bench of ITAT in assessee’s own case [2013 (4) TMI 643 - ITAT Pune] we allow the claim of assessee that IT support services is neither royalty or fees for Technical Services (FTS), Thus, the issue is allowed on merits. Thus, the appeal of Revenue is dismissed
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