ITAT slams AO for initiating reassessment on finding in earlier years which was set aside in appella

IT/ILT : Where Assessing Officer relying upon his finding in earlier assessment year, took a view that amount received by assessee, a Russian Company, for rendering 'offshore services contract' in connection with setting up a nuclear power plant in India, was taxable as 'royalty' under Articler 12 of India - Russian Federation DTAA, in view of fact that said finding of Assessing Officer had been set aside in appellate proceedings, impugned reassessment proceedings being without any basis, deserv