https://www.taxtmi.com/caselaws?id=250260 Reassessment is sustainable where survey material and recorded statements provide tangible, live nexus for the belief that income has escaped assessment, including material suggesting a business connection and permanent establishment in India. A prior transfer pricing order confined to an Indian subsidiary does not prevent reopening on the separate question whether the foreign principal itself had a permanent establishment and attributable profits in India. At the reopening stage, the sufficiency of the material is not finally adjudicated; only the existence of relevant material supporting the belief is examined. en-us Tue, 05 Aug 2014 00:00:00 +0530 Thu, 19 Feb 2015 16:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=250260 Reassessment is sustainable where survey material and recorded statements provide tangible, live nexus for the belief that income has escaped assessment, including material suggesting a business connection and permanent establishment in India. A prior transfer pricing order confined to an Indian subsidiary does not prevent reopening on the separate question whether the foreign principal itself had a permanent establishment and attributable profits in India. At the reopening stage, the sufficiency of the material is not finally adjudicated; only the existence of relevant material supporting the belief is examined. Case-Laws Income Tax Tue, 05 Aug 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=250260