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    <title>2014 (1) TMI 1356 - ITAT CHENNAI</title>
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    <description>A Malaysian branch registered and operating as an independent establishment was treated as a permanent establishment under the India-Malaysia DTAA, so income attributable to assets and activities outside India was held taxable only in Malaysia and not in India. The challenge to reopening under section 148 was also rejected because no substantive objection was pressed and the reassessment finding was found detailed and justified. The assessments were therefore left undisturbed on the reopening issue.</description>
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      <description>A Malaysian branch registered and operating as an independent establishment was treated as a permanent establishment under the India-Malaysia DTAA, so income attributable to assets and activities outside India was held taxable only in Malaysia and not in India. The challenge to reopening under section 148 was also rejected because no substantive objection was pressed and the reassessment finding was found detailed and justified. The assessments were therefore left undisturbed on the reopening issue.</description>
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