https://www.taxtmi.com/caselaws?id=203637 Reassessment under section 147 was upheld because the recorded reasons supplied relevant material to form a reasonable belief of escapement, and a section 143(1) intimation did not create a change-of-opinion bar. Income from production and sale of parent seeds was treated as arising from an integrated commercial activity, so it was not fully able as agricultural income and was aligned with the connected year's treatment. The Indian branch was held to constitute a permanent establishment where research and seed-production functions formed a core business activity; profits attributable to that permanent establishment were taxable in India, but attribution had to be recomputed on arm's length principles after fresh examination. en-us Thu, 24 Dec 2009 00:00:00 +0530 Tue, 14 Aug 2012 15:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=203637 Reassessment under section 147 was upheld because the recorded reasons supplied relevant material to form a reasonable belief of escapement, and a section 143(1) intimation did not create a change-of-opinion bar. Income from production and sale of parent seeds was treated as arising from an integrated commercial activity, so it was not fully able as agricultural income and was aligned with the connected year's treatment. The Indian branch was held to constitute a permanent establishment where research and seed-production functions formed a core business activity; profits attributable to that permanent establishment were taxable in India, but attribution had to be recomputed on arm's length principles after fresh examination. Case-Laws Income Tax Thu, 24 Dec 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=203637