Change of opinion alone fails for reassessment

The Delhi ITAT has reinforced a key limit on reassessment. The Revenue cannot reopen a completed assessment after four years merely because it later takes a different view.

Where the transaction was fully disclosed and examined originally, reopening requires both a failure of disclosure and a valid jurisdictional basis. 

The Tribunal also held that an AE subsidy linked to business operations forms part of operating income for transfer pricing purposes.