https://www.taxtmi.com/caselaws?id=184709 Reassessment under section 147 was upheld because the original return had been processed only under section 143(1), so an intimation did not bar reopening where there was reason to believe income had escaped assessment. On the permanent establishment issue, the Tribunal followed the earlier year's factual finding that the Indian entity was not a fixed place, office, or agency PE, and deleted attribution of profits from sales to India. Interest under section 234B was also deleted for the foreign assessee because tax was deductible at source by the payer, with consequential relief in respect of sections 234A and 234C. en-us Fri, 18 Jan 2013 00:00:00 +0530 Thu, 08 Jun 2017 14:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=184709 Reassessment under section 147 was upheld because the original return had been processed only under section 143(1), so an intimation did not bar reopening where there was reason to believe income had escaped assessment. On the permanent establishment issue, the Tribunal followed the earlier year's factual finding that the Indian entity was not a fixed place, office, or agency PE, and deleted attribution of profits from sales to India. Interest under section 234B was also deleted for the foreign assessee because tax was deductible at source by the payer, with consequential relief in respect of sections 234A and 234C. Case-Laws Income Tax Fri, 18 Jan 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=184709