Precilion Holdings Limited v. DCIT( 2019) 412 ITR 43/262 Taxman 228 / 177 DTR 441 /(2020) 314 CTR 507(Bom)(HC), www.itatonline.org Editorial : SLP of revenue is dismissed ,DCIT v Precilion Holdings Ltd ( 2019) 418 ITR 15 (St)/( 2020) 269 Taxman 488

S. 147: Reassessment -After the expiry of four years -If the AO is of the opinion that the issue requires verification, it tantamounts to fishing or roving inquiry. He is not permitted to reopen merely because in the later year, he took a different view on the basis of similar material-.Even if the question of taxing interest income under the DTAA was not in the mind of the AO when he passed the assessment, he cannot reopen if there is no failure to disclose truly and fully all material facts- Reassessment is held to be not valid-DTAA-India -Cyprus . [ S.148,, Art. 11(2). ]