https://www.taxtmi.com/caselaws?id=214171 The Tribunal upheld the jurisdiction of the Assessing Officer to issue a notice under section 148, citing sufficient reasons to believe income had escaped assessment. It determined that payments received by the assessee from its Indian subsidiary constituted fees for technical services, not mere reimbursements. The finding that the Indian subsidiary constituted a permanent establishment of the assessee in India was upheld. The Tribunal directed a reevaluation of interest levied under sections 234B and 234D, allowing the appeal in part for statistical purposes. en-us Fri, 11 May 2012 00:00:00 +0530 Thu, 23 May 2013 18:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=214171 The Tribunal upheld the jurisdiction of the Assessing Officer to issue a notice under section 148, citing sufficient reasons to believe income had escaped assessment. It determined that payments received by the assessee from its Indian subsidiary constituted fees for technical services, not mere reimbursements. The finding that the Indian subsidiary constituted a permanent establishment of the assessee in India was upheld. The Tribunal directed a reevaluation of interest levied under sections 234B and 234D, allowing the appeal in part for statistical purposes. Case-Laws Income Tax Fri, 11 May 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=214171