In the result, the appeal filed by the assessee is allowed
194J on roaming charges paid to other\nnetwork operators. These issues were different from the subject matter of\nreassessment order. The Delhi High Court held that the subject matter is\ndifferent since the Commissioner has found error in regular assessment\norder, hence limitation shall commence for regular assessment order.”\n3.3 In Ashok Buildcon Ltd. Vs. ACIT