https://www.taxtmi.com/caselaws?id=380118 Where reassessment was based only on an alleged permanent establishment and income attribution, the Tribunal held that the foundation of the reassessment no longer survived after the Supreme Court quashed the underlying notices. The Tribunal noted that, once the arm's length principle had been satisfied, no further profit attribution could be made merely on the basis of a permanent establishment allegation. As the impugned reassessment orders stemmed from those quashed notices, they could not be sustained and the appeals became infructuous. en-us Fri, 10 May 2019 00:00:00 +0530 Mon, 13 May 2019 13:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=380118 Where reassessment was based only on an alleged permanent establishment and income attribution, the Tribunal held that the foundation of the reassessment no longer survived after the Supreme Court quashed the underlying notices. The Tribunal noted that, once the arm's length principle had been satisfied, no further profit attribution could be made merely on the basis of a permanent establishment allegation. As the impugned reassessment orders stemmed from those quashed notices, they could not be sustained and the appeals became infructuous. Case-Laws Income Tax Fri, 10 May 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=380118