Mere Change of Opinion not Necessary Ingredient For Reassessment: ITAT quashes Reassessment on Software License Fee [Read Order]

The Tribunal held that the reopening was based on a mere change of opinion and which has not satisfied the necessary ingredients for initiating reassessment proceedings
Software License - ITAT Quashes - Reassessment - taxscan

The Chennai Bench of the Income Tax Appellate Tribunal ( ITAT ) has quashed a reassessment order and ruled that the reopening of the assessment was invalid due to it being based on a mere change of opinion. The case involved the treatment of software license fee expenses as capital expenditure, which the Assessing Officer…

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