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 - AO has proceeded to reopen the assessment on the basis of wrong appreciation of facts by mentioning that the assessment is proposed to be made for the first time whereas the facts stood otherwise - Approval has been given in a mechanical manner without appreciating the facts properly and there is complete non-application of mind by the superior authorities. - reassessment proceedings have to be quashed - AT
Reopening of assessment u/s 147 - AO has proceeded to reopen the assessment on the basis of wrong appreciation of facts by mentioning that the assessment is proposed to be made for the first time whereas the facts stood otherwise - Approval has been given in a mechanical manner without appreciating the facts properly and there is complete non-application of mind by the superior authorities. - reassessment proceedings have to be quashed - AT
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