https://www.taxtmi.com/caselaws?id=375498 Reassessment under section 148 was held unsustainable where the alleged basis was the existence of a permanent establishment in India and escapement of income, but the Supreme Court in the assessee's own case had already ruled that, once the arm's length price mechanism had been applied, no further profit attribution could be made merely on that basis. In view of that binding position, the reopening could not be supported, and the reassessment proceedings and consequential orders failed with the invalid notice. en-us Thu, 13 Dec 2018 00:00:00 +0530 Wed, 20 Feb 2019 06:37:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=375498 Reassessment under section 148 was held unsustainable where the alleged basis was the existence of a permanent establishment in India and escapement of income, but the Supreme Court in the assessee's own case had already ruled that, once the arm's length price mechanism had been applied, no further profit attribution could be made merely on that basis. In view of that binding position, the reopening could not be supported, and the reassessment proceedings and consequential orders failed with the invalid notice. Case-Laws Income Tax Thu, 13 Dec 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=375498