https://www.taxtmi.com/caselaws?id=278473 A prima facie belief based on relevant material was sufficient to sustain reassessment under sections 147 and 148 where the Assessing Officer had information indicating possible escapement of income. On treaty taxation, business income could be taxed in India only if the Indian agent habitually had and exercised authority to conclude contracts or otherwise constituted a permanent establishment under the applicable definition. Mere liaison, communication, or commercial support functions did not establish such authority, and the service-PE clause was also inapplicable on the facts. The reopening was upheld, but the business additions were deleted because no permanent establishment or taxable business profits in India were proved. en-us Tue, 19 Apr 2005 00:00:00 +0530 Tue, 05 Feb 2019 13:09:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=278473 A prima facie belief based on relevant material was sufficient to sustain reassessment under sections 147 and 148 where the Assessing Officer had information indicating possible escapement of income. On treaty taxation, business income could be taxed in India only if the Indian agent habitually had and exercised authority to conclude contracts or otherwise constituted a permanent establishment under the applicable definition. Mere liaison, communication, or commercial support functions did not establish such authority, and the service-PE clause was also inapplicable on the facts. The reopening was upheld, but the business additions were deleted because no permanent establishment or taxable business profits in India were proved. Case-Laws Income Tax Tue, 19 Apr 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=278473