https://www.taxtmi.com/caselaws?id=220814 Reassessment was upheld because the reopening was supported by prima facie material and a rational nexus to escaped income. The Commissioner (Appeals) could validly enhance the assessment under section 251 by bringing network equipment royalty to tax, as it formed part of the same subject-matter of assessment. Royalty from non-resident OEMs was held not taxable in India under section 9(1)(vi)(c) because the Revenue failed to show use of the licensed rights for a business carried on in India or for income from an Indian source. Section 234A interest remained mandatory, while section 234B interest was deleted. en-us Thu, 31 Jan 2013 00:00:00 +0530 Fri, 19 Dec 2025 10:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=220814 Reassessment was upheld because the reopening was supported by prima facie material and a rational nexus to escaped income. The Commissioner (Appeals) could validly enhance the assessment under section 251 by bringing network equipment royalty to tax, as it formed part of the same subject-matter of assessment. Royalty from non-resident OEMs was held not taxable in India under section 9(1)(vi)(c) because the Revenue failed to show use of the licensed rights for a business carried on in India or for income from an Indian source. Section 234A interest remained mandatory, while section 234B interest was deleted. Case-Laws Income Tax Thu, 31 Jan 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=220814