https://www.taxtmi.com/caselaws?id=246801 Reassessment under section 148 was upheld where survey material indicated undisclosed India-taxable income and the return was filed only in response to notice. On the merits, active involvement of Indian personnel in bidding, contracting, installation and technical services supported business connection and multiple forms of permanent establishment in India, so taxability under the Act and the DTAA was sustained. Embedded software supplied as part of a single equipment contract, with only a limited licence and no transfer of copyright rights, was treated as a copyrighted article and not royalty; the amount was to be recomputed as business income. Interest under section 234B was remanded for fresh consideration. en-us Fri, 21 Mar 2014 00:00:00 +0530 Wed, 23 Apr 2014 10:12:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=246801 Reassessment under section 148 was upheld where survey material indicated undisclosed India-taxable income and the return was filed only in response to notice. On the merits, active involvement of Indian personnel in bidding, contracting, installation and technical services supported business connection and multiple forms of permanent establishment in India, so taxability under the Act and the DTAA was sustained. Embedded software supplied as part of a single equipment contract, with only a limited licence and no transfer of copyright rights, was treated as a copyrighted article and not royalty; the amount was to be recomputed as business income. Interest under section 234B was remanded for fresh consideration. Case-Laws Income Tax Fri, 21 Mar 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=246801