https://www.taxtmi.com/caselaws?id=349524 Reassessment proceedings were treated as unsustainable because the objections to reopening were not disposed of before completion of assessment, and the record did not show any taxable income accruing or arising in India from the assessee's liaison activities. The liaison office operated within RBI permission, which allowed only liaison work for recruiting Indian crew and barred any income-earning consultancy or commercial activity. The assessment also relied on receipts of another company rather than identifying income actually earned by the assessee. On these facts, the reopening under sections 147 and 148 was held invalid and the addition could not be sustained. en-us Mon, 11 Sep 2017 00:00:00 +0530 Mon, 16 Oct 2017 09:18:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=349524 Reassessment proceedings were treated as unsustainable because the objections to reopening were not disposed of before completion of assessment, and the record did not show any taxable income accruing or arising in India from the assessee's liaison activities. The liaison office operated within RBI permission, which allowed only liaison work for recruiting Indian crew and barred any income-earning consultancy or commercial activity. The assessment also relied on receipts of another company rather than identifying income actually earned by the assessee. On these facts, the reopening under sections 147 and 148 was held invalid and the addition could not be sustained. Case-Laws Income Tax Mon, 11 Sep 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=349524