https://www.taxtmi.com/caselaws?id=205037 Reassessment under section 147 was upheld because the recorded material provided a prima facie basis to believe income had escaped assessment. Separate supply and service agreements for the same modernization project were treated as one composite contract, since the obligations, milestones and commercial substance were integrated. No fixed place permanent establishment arose merely from review visits; it arose only when goods were cleared in India and handed over for installation. Offshore supply and software receipts were therefore not taxable in India for the relevant year, while installation-linked income for the Mumbai project remained taxable. Consideration could be bifurcated between equipment and software on objective estimation, and later advance rulings were only persuasive. en-us Fri, 17 Jun 2011 00:00:00 +0530 Fri, 16 Oct 2015 17:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=205037 Reassessment under section 147 was upheld because the recorded material provided a prima facie basis to believe income had escaped assessment. Separate supply and service agreements for the same modernization project were treated as one composite contract, since the obligations, milestones and commercial substance were integrated. No fixed place permanent establishment arose merely from review visits; it arose only when goods were cleared in India and handed over for installation. Offshore supply and software receipts were therefore not taxable in India for the relevant year, while installation-linked income for the Mumbai project remained taxable. Consideration could be bifurcated between equipment and software on objective estimation, and later advance rulings were only persuasive. Case-Laws Income Tax Fri, 17 Jun 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=205037