https://www.taxtmi.com/caselaws?id=249137 Reopening of assessment beyond four years was upheld where the recorded reasons alleged failure to fully and truly disclose material facts necessary for assessment. The dispute turned on factual questions, including whether the foreign commission recipient had a permanent establishment in India and whether the commission was separately disclosed, and the assessee did not produce supporting material at the objections stage. The reasons also referred to differential accounting treatment between foreign and local commission and the original non-examination of tax deduction at source. On that basis, the notice was not found to be without jurisdiction at the writ stage, and the reopening notice and rejection of objections were not interfered with. en-us Mon, 16 Jun 2014 00:00:00 +0530 Fri, 04 Jul 2014 20:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=249137 Reopening of assessment beyond four years was upheld where the recorded reasons alleged failure to fully and truly disclose material facts necessary for assessment. The dispute turned on factual questions, including whether the foreign commission recipient had a permanent establishment in India and whether the commission was separately disclosed, and the assessee did not produce supporting material at the objections stage. The reasons also referred to differential accounting treatment between foreign and local commission and the original non-examination of tax deduction at source. On that basis, the notice was not found to be without jurisdiction at the writ stage, and the reopening notice and rejection of objections were not interfered with. Case-Laws Income Tax Mon, 16 Jun 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=249137