https://www.taxtmi.com/caselaws?id=252785 Reassessment under sections 147 and 148 was sustained where the recorded reasons and material available at initiation gave a prima facie basis to believe income had escaped assessment, and the sufficiency of that material could not be tested at reopening stage. The Indian branch was held to be a permanent establishment under the India-US DTAA because its fixed place in India carried out substantial engineering design, drafting and structural work through qualified employees, and the activities were not preparatory or auxiliary. Profit attribution to the Indian PE on a 50% basis was upheld under Rule 10 on the facts, and the foreign-incorporated entity was correctly treated as a foreign company under domestic law. en-us Fri, 31 Oct 2014 00:00:00 +0530 Tue, 04 Nov 2014 06:05:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=252785 Reassessment under sections 147 and 148 was sustained where the recorded reasons and material available at initiation gave a prima facie basis to believe income had escaped assessment, and the sufficiency of that material could not be tested at reopening stage. The Indian branch was held to be a permanent establishment under the India-US DTAA because its fixed place in India carried out substantial engineering design, drafting and structural work through qualified employees, and the activities were not preparatory or auxiliary. Profit attribution to the Indian PE on a 50% basis was upheld under Rule 10 on the facts, and the foreign-incorporated entity was correctly treated as a foreign company under domestic law. Case-Laws Income Tax Fri, 31 Oct 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=252785