https://www.taxtmi.com/caselaws?id=184721 Reopening under section 147 was valid because the recorded reasons were founded on later-year assessment material and, at the reopening stage, the Assessing Officer needed only reason to believe that income had escaped assessment. Income from India was taxable on accrual basis, not cash basis, because the non-resident maintained mercantile accounts and could not adopt a separate cash method only for Indian receipts. The Indian agent was not independent, having acted under close control for liaison, promotion and order solicitation; a business connection and dependent agent permanent establishment therefore existed. Only 10% of the profit from supply of spares was attributable to the Indian permanent establishment. en-us Fri, 19 Mar 2010 00:00:00 +0530 Mon, 18 Jul 2016 17:03:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=184721 Reopening under section 147 was valid because the recorded reasons were founded on later-year assessment material and, at the reopening stage, the Assessing Officer needed only reason to believe that income had escaped assessment. Income from India was taxable on accrual basis, not cash basis, because the non-resident maintained mercantile accounts and could not adopt a separate cash method only for Indian receipts. The Indian agent was not independent, having acted under close control for liaison, promotion and order solicitation; a business connection and dependent agent permanent establishment therefore existed. Only 10% of the profit from supply of spares was attributable to the Indian permanent establishment. Case-Laws Income Tax Fri, 19 Mar 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=184721