Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
Income deemed or accrue or arise in India - liaison office - Permanent Establishment (PE) - Revenue though vehemently submitted that liaison office was negotiating price and doing sales activity in India, however, has not brought any sales agreement in support of the claim. It is highly doubtful that sales transaction of such a large scale can be conducted internationally without any written agreement. - the liaison office in Mumbai does not constitute PE of the assessee in India under the provisions of DTAA. - AT
Income deemed or accrue or arise in India - liaison office - Permanent Establishment (PE) - Revenue though vehemently submitted that liaison office was negotiating price and doing sales activity in India, however, has not brought any sales agreement in support of the claim. It is highly doubtful that sales transaction of such a large scale can be conducted internationally without any written agreement. - the liaison office in Mumbai does not constitute PE of the assessee in India under the provisions of DTAA. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4915 
