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In course of re-assessment proceedings, the AO called upon the assessee to explain why tax was not deducted at source while making payment of Rs. 2,14,92,188, to its AE.

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Section 147 of the Income Tax Act,1961– Reassessment– Reopening of assessment by re-examination of material already examined in original assessment under section 143(3) was not valid. Further , no addition having been made on item specified in reasons recorded but addition made on another item of income, reassessment was not sustainable – Eagle Burgmann India P. Ltd. Vs. Deputy Commissioner of income tax [2020] 203 TTJ (Mumbai) 477

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