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...
The HC held that the reopening of assessment beyond four years was without jurisdiction as the reasons did not disclose any material facts that the assessee failed to disclose during the original assessment proceedings. Merely reproducing the proviso's wordings does not satisfy the jurisdictional condition for reopening. The reasons recorded were based on the assessee's case records filed during the assessment, which is impermissible for reopening after four years under the first proviso to Section 147. The HC ruled in favor of the assessee.
The HC held that the reopening of assessment beyond four years was without jurisdiction as the reasons did not disclose any material facts that the assessee failed to disclose during the original assessment proceedings. Merely reproducing the proviso's wordings does not satisfy the jurisdictional condition for reopening. The reasons recorded were based on the assessee's case records filed during the assessment, which is impermissible for reopening after four years under the first proviso to Section 147. The HC ruled in favor of the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
