ITAT Quashes Reassessment as Reopening Was Based on Mere Change of Opinion

Van Oord Dredging and Marine Contractors BV Vs ADIT(IT)-2(2) (ITAT Mumbai) The assessee, a company incorporated in the Netherlands and engaged in international dredging activities, filed appeals before the ITAT Mumbai for Assessment Years 2005-06 and 2007-08 challenging the reopening of assessments, the validity of the assessment orders, and the taxation of management service fees as royalty. The assessee had received management service fees from its Indian associated concern, Van Oord India Private Limited (VOIPL). It did not offer these receipts to tax, contending that the services rendered ...