Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
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Reopening of assessment u/s 147 - there was a specific note in the accounts and schedule 28 to the accounts was quite clear. If the accounts were before the assessing officer and several queries were raised pertaining even to the royalty and matters connected therewith, it is difficult to accept that the additional income representing the excess of the amount earmarked as provision and the amount actually paid out would not have been noticed. - Notice u/s 148 stayed.
Reopening of assessment u/s 147 - there was a specific note in the accounts and schedule 28 to the accounts was quite clear. If the accounts were before the assessing officer and several queries were raised pertaining even to the royalty and matters connected therewith, it is difficult to accept that the additional income representing the excess of the amount earmarked as provision and the amount actually paid out would not have been noticed. - Notice u/s 148 stayed.
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