The assessee has paid Machine Hire Charges to various contractors or sub-contractors were fully disclosed not only in books of account and Audit Reports furnished by Tax Auditor, but also by way of replies to notice issued by Assessing Authority. During course of original assessment proceeding, it was also contended while giving reply to audit objection that payments, having been made as machine hire charges, did not amount to rentals and thereby did not attract section 194I. The Reassessment proceedings were initiated for failure to deduct tax at source. Tribunal held that   since aspect of non-deduction of TDS on machine hire charges attracting section 194I was very much discussed by Assessing Authority during original assessment proceeding, on a mere change of opinion, Assessing Authority could not have invoked reassessment proceedings under section 147/148 beyond period of four years after end of relevant assessment year to disallow impugned amount. Order of Tribunal is affirmed. (AY. 2007-08)