https://www.taxtmi.com/caselaws?id=219594 Reassessment under Sections 147 and 148 requires a prima facie belief that income escaped assessment, based on material with a live nexus to that belief. An Indian subsidiary providing services exclusively to a non-resident may prima facie support a business connection and permanent establishment for reopening purposes. An interest-income ground may also sustain reopening where interest was charged in the relevant assessment year. Conversely, characterising salaries paid to seconded employees as fees for technical services requires supporting material and cannot rest on conjecture. Reopening remains valid where other recorded reasons independently provide prima facie grounds, despite one unsustainable reason. en-us Wed, 12 Dec 2012 00:00:00 +0530 Sat, 26 Oct 2013 13:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=219594 Reassessment under Sections 147 and 148 requires a prima facie belief that income escaped assessment, based on material with a live nexus to that belief. An Indian subsidiary providing services exclusively to a non-resident may prima facie support a business connection and permanent establishment for reopening purposes. An interest-income ground may also sustain reopening where interest was charged in the relevant assessment year. Conversely, characterising salaries paid to seconded employees as fees for technical services requires supporting material and cannot rest on conjecture. Reopening remains valid where other recorded reasons independently provide prima facie grounds, despite one unsustainable reason. Case-Laws Income Tax Wed, 12 Dec 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=219594