https://www.taxtmi.com/caselaws?id=69474 In a turnkey project with single-bidder responsibility, the first appellate authority's enhancement power under section 251 was treated as co-terminous with the Assessing Officer's and was not confined to items expressly added in assessment. The record was also held to show adequate disclosure and opportunity, so no breach of natural justice arose. The contracts were treated as one composite arrangement, the subsidiary as a tax device, and the corporate veil was lifted. On that basis, the enterprise was found to have a permanent establishment and business connection in India, with tax restricted to profits attributable to Indian operations. Interest under section 234B remained chargeable, but had to be recomputed after reducing tax deductible at source under section 209. en-us Fri, 11 May 2007 00:00:00 +0530 Fri, 14 Jun 2013 17:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=69474 In a turnkey project with single-bidder responsibility, the first appellate authority's enhancement power under section 251 was treated as co-terminous with the Assessing Officer's and was not confined to items expressly added in assessment. The record was also held to show adequate disclosure and opportunity, so no breach of natural justice arose. The contracts were treated as one composite arrangement, the subsidiary as a tax device, and the corporate veil was lifted. On that basis, the enterprise was found to have a permanent establishment and business connection in India, with tax restricted to profits attributable to Indian operations. Interest under section 234B remained chargeable, but had to be recomputed after reducing tax deductible at source under section 209. Case-Laws Income Tax Fri, 11 May 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=69474