https://www.taxtmi.com/caselaws?id=243845 Reassessment under Sections 147 and 148 was sustained where no returns had been filed, no regular assessment under Section 143(3) existed, and the recorded reasons showed a live nexus to escaped income. The Court also recognised business connection in India under Section 9(1)(i) because the Indian company provided support for contracting and performance, but only income attributable to Indian operations could be taxed. No permanent establishment arose under Article 5 of the India-US DTAA, as mere ownership or control of a subsidiary was insufficient and the treaty tests were not met. The Indian subsidiary's income was not taxable again in the foreign assessees' hands, and the revised apportionment method was upheld. en-us Wed, 05 Feb 2014 00:00:00 +0530 Mon, 02 Mar 2026 11:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=243845 Reassessment under Sections 147 and 148 was sustained where no returns had been filed, no regular assessment under Section 143(3) existed, and the recorded reasons showed a live nexus to escaped income. The Court also recognised business connection in India under Section 9(1)(i) because the Indian company provided support for contracting and performance, but only income attributable to Indian operations could be taxed. No permanent establishment arose under Article 5 of the India-US DTAA, as mere ownership or control of a subsidiary was insufficient and the treaty tests were not met. The Indian subsidiary's income was not taxable again in the foreign assessees' hands, and the revised apportionment method was upheld. Case-Laws Income Tax Wed, 05 Feb 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=243845