https://www.taxtmi.com/caselaws?id=258964 Reassessment beyond four years requires reasons to believe that income escaped assessment because the assessee failed to disclose fully and truly all material facts necessary for assessment. Disclosure of payments and accounts did not disclose that the foreign payee had a permanent establishment in India or that remittances could be taxable in India. That non-disclosure was treated as material to reassessment jurisdiction, with the recorded reasons having a live nexus to escaped income. Transfer-pricing and India-Korea DTAA issues were not material at the notice stage and remained open for reassessment proceedings. The reopening notice and rejection of objections were treated as valid. en-us Wed, 22 Apr 2015 00:00:00 +0530 Sat, 07 Nov 2015 16:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=258964 Reassessment beyond four years requires reasons to believe that income escaped assessment because the assessee failed to disclose fully and truly all material facts necessary for assessment. Disclosure of payments and accounts did not disclose that the foreign payee had a permanent establishment in India or that remittances could be taxable in India. That non-disclosure was treated as material to reassessment jurisdiction, with the recorded reasons having a live nexus to escaped income. Transfer-pricing and India-Korea DTAA issues were not material at the notice stage and remained open for reassessment proceedings. The reopening notice and rejection of objections were treated as valid. Case-Laws Income Tax Wed, 22 Apr 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=258964