Delhi High Court Judgments — 2024

The High Court upheld the ITAT's decision, concluding that the reasons recorded by the AO for reopening the assessment contained material errors, which indicated a lack of application of mind. Consequently, the reopening of the assessment was deemed invalid, and no substantial question of law arose.

The ITAT, following decisions for earlier assessment years, held that the receipts were not chargeable as fees for technical services. The High Court, noting its own previous decision in the assessee's case for an earlier year, found no substantial question of law arose and dismissed the Revenue's appeal.