https://www.taxtmi.com/caselaws?id=65332 Reassessment may validly proceed under section 147 where only an intimation under section 143(1)(a) was issued, because such intimation is not an assessment and does not bar reopening. Payments to UK non-residents for advisory, assessment, surveillance, liaison and audit services were not taxable in India where the services did not make available technical knowledge, experience, skill, know-how or processes. Professional-service income was not taxable absent the requisite Indian presence or fixed base, and business profits were not taxable without a permanent establishment. Consequently, no tax deduction obligation arose and disallowance for non-deduction was unsustainable. en-us Wed, 22 Dec 2004 00:00:00 +0530 Wed, 19 Jun 2024 14:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=65332 Reassessment may validly proceed under section 147 where only an intimation under section 143(1)(a) was issued, because such intimation is not an assessment and does not bar reopening. Payments to UK non-residents for advisory, assessment, surveillance, liaison and audit services were not taxable in India where the services did not make available technical knowledge, experience, skill, know-how or processes. Professional-service income was not taxable absent the requisite Indian presence or fixed base, and business profits were not taxable without a permanent establishment. Consequently, no tax deduction obligation arose and disallowance for non-deduction was unsustainable. Case-Laws Income Tax Wed, 22 Dec 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=65332