No reassessment to disallow exp. due to TDS default by treating it as royalty if its details were di

IT/ILT : Where at time of making assessment, assessee disclosed all material facts showing that software licence fee paid to foreign company was in nature of revenue expenditure, AO could not initiate reassessment proceedings subsequently merely on basis of change of opinion that fee so paid was in nature of royalty and thus, assessee was required to deduct tax at source while making said payment