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Sunday, May 28, 2017

Reopening based on reappraisal of existing material is invalid

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The AO examined the nature of the transactions involving the Assessee and the payments received therefor. The reopening was not based on any fresh material. By revisiting the same materials the successor AO now concluded that the payments received by the Assessee pursuant to the O&M Agreements should be treated as FTS.

May 28, 2017 at 09:21AM

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from editor2

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