Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
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Reopening of assessment u/s 147 - Penny stock transaction - It is settled law that sufficiency or adequacy of the reasons for the issuance of the notice for reopening of the assessment is not required to be gone into at this stage of the reopening. It can never be said that the final outcome of the proceedings has been derived at by the authority by issuing a notice for reopening. - if the AO was satisfied to harbour reasons to believe that there was escapement of income and if on such basis, he has exercised his powers u/s 147, 148 of the Income Tax Act, 1961, no fault can be found. - HC
Reopening of assessment u/s 147 - Penny stock transaction - It is settled law that sufficiency or adequacy of the reasons for the issuance of the notice for reopening of the assessment is not required to be gone into at this stage of the reopening. It can never be said that the final outcome of the proceedings has been derived at by the authority by issuing a notice for reopening. - if the AO was satisfied to harbour reasons to believe that there was escapement of income and if on such basis, he has exercised his powers u/s 147, 148 of the Income Tax Act, 1961, no fault can be found. - HC
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