Notice Under Section 148 Invalid When Tax Issue Is Concluded in Earlier Years: ITAT Delhi

Thaicom Public Company Limited Vs ACIT (ITAT Delhi)

The Delhi Bench of the Income Tax Appellate Tribunal dealt with an appeal challenging the validity of reassessment proceedings initiated for Assessment Year 2018–19 under sections 147 read with 144C(13) of the Income-tax Act, 1961. The reassessment was triggered by a notice issued under section 148A(b) on the ground that income received from Indian customers for providing digital broadcast services through transponders had not been offered to tax. The Assessing Officer treated such receipts as royalty taxable under section 9(1)(

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