https://www.taxtmi.com/caselaws?id=208948 Reopening on the representative assessee was upheld because escapement is tested at the stage reasons for reopening are recorded, and parallel proceedings against the foreign principal do not bar assessment in a representative capacity under sections 161 and 166. Treaty relief under Article 8 of the India-Singapore DTAA was unavailable because the foreign principal was treated as a commission agent rather than an enterprise operating ships in international traffic. The Article 7 position required fresh examination by the Assessing Officer in line with earlier directions, leaving that aspect open for reconsideration. en-us Fri, 26 Feb 2010 00:00:00 +0530 Mon, 05 Aug 2013 13:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=208948 Reopening on the representative assessee was upheld because escapement is tested at the stage reasons for reopening are recorded, and parallel proceedings against the foreign principal do not bar assessment in a representative capacity under sections 161 and 166. Treaty relief under Article 8 of the India-Singapore DTAA was unavailable because the foreign principal was treated as a commission agent rather than an enterprise operating ships in international traffic. The Article 7 position required fresh examination by the Assessing Officer in line with earlier directions, leaving that aspect open for reconsideration. Case-Laws Income Tax Fri, 26 Feb 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=208948