https://www.taxtmi.com/caselaws?id=357503 The ITAT Delhi decision examined reopening under sections 147 and 148, permanent establishment exposure from seconded expatriate employees, profit attribution, interest under sections 234A and 234B, and TDS credit. Reassessment was upheld because the original returns had not disclosed royalty and fee for technical services income, giving a valid basis to believe income had escaped assessment; Explanation 3 to section 147 allowed consideration of other issues. No fixed place, dependent agent, or service permanent establishment was found, as the secondees' work was limited to coordination and business support for the Indian subsidiary, so estimated attribution and consequential interest failed. TDS credit was to be verified and granted if statutory conditions were met. en-us Thu, 22 Mar 2018 00:00:00 +0530 Tue, 14 Oct 2025 13:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=357503 The ITAT Delhi decision examined reopening under sections 147 and 148, permanent establishment exposure from seconded expatriate employees, profit attribution, interest under sections 234A and 234B, and TDS credit. Reassessment was upheld because the original returns had not disclosed royalty and fee for technical services income, giving a valid basis to believe income had escaped assessment; Explanation 3 to section 147 allowed consideration of other issues. No fixed place, dependent agent, or service permanent establishment was found, as the secondees' work was limited to coordination and business support for the Indian subsidiary, so estimated attribution and consequential interest failed. TDS credit was to be verified and granted if statutory conditions were met. Case-Laws Income Tax Thu, 22 Mar 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=357503