https://www.taxtmi.com/caselaws?id=64368 A foreign enterprise was held to have validly faced reopening because the Assessing Officer had prima facie material suggesting India operations and non-filing of returns, and the sufficiency of that material was not to be examined at the reopening stage. The Tribunal also found a business connection and a permanent establishment in India because the Indian subsidiary carried out core marketing and sales functions, secured orders, and used fixed office space at the enterprise's disposal. However, profit attribution to India had to reflect actual functional contribution, so the earlier 75% attribution was reduced to 35%. Interest under sections 234A and 234B was held chargeable as consequential and mandatory. en-us Fri, 26 Oct 2007 00:00:00 +0530 Tue, 30 Jan 2024 13:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=64368 A foreign enterprise was held to have validly faced reopening because the Assessing Officer had prima facie material suggesting India operations and non-filing of returns, and the sufficiency of that material was not to be examined at the reopening stage. The Tribunal also found a business connection and a permanent establishment in India because the Indian subsidiary carried out core marketing and sales functions, secured orders, and used fixed office space at the enterprise's disposal. However, profit attribution to India had to reflect actual functional contribution, so the earlier 75% attribution was reduced to 35%. Interest under sections 234A and 234B was held chargeable as consequential and mandatory. Case-Laws Income Tax Fri, 26 Oct 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=64368