The Tribunal held that the O in the course of assessment for A.Y. 2011-12 having realized that the assessee for the A.Y. 2009-10 had not deducted tax under section 194H from discount which constituted commission and there being no application of mind by AO to this issue, assessment for A.Y. 2009-10 was validly reopened by AO. (AY.2009-10)
Bharat Sanchar Nigam Ltd. v. Addl. CIT (2018) 191 TTJ 393 (Delhi)(Trib.)
S. 147 : Reassessment – Issue was not examined during assessment hence reassessment was held to be valid. [ S.194H ]