https://www.taxtmi.com/caselaws?id=205927 The court dismissed the writ petitions, upholding the validity of the reassessment proceedings initiated under Section 147 based on prima facie reasons to believe that income had escaped assessment. It clarified that tax liability and permanent establishment issues would be determined in the assessment proceedings, emphasizing that certificates issued under Sections 195 and 197 are provisional and do not prevent reassessment. The court did not provide a final opinion on these matters, emphasizing the interim nature of the certificates and the assessing officer's authority to initiate reassessment proceedings. en-us Mon, 25 Apr 2011 00:00:00 +0530 Wed, 23 Jan 2013 18:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=205927 The court dismissed the writ petitions, upholding the validity of the reassessment proceedings initiated under Section 147 based on prima facie reasons to believe that income had escaped assessment. It clarified that tax liability and permanent establishment issues would be determined in the assessment proceedings, emphasizing that certificates issued under Sections 195 and 197 are provisional and do not prevent reassessment. The court did not provide a final opinion on these matters, emphasizing the interim nature of the certificates and the assessing officer's authority to initiate reassessment proceedings. Case-Laws Income Tax Mon, 25 Apr 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=205927