https://www.taxtmi.com/caselaws?id=385464 The Tribunal dismissed the grounds challenging the reassessment proceedings under Section 147 of the Income Tax Act for the years 2004-05 to 2010-11. Regarding the existence of a Permanent Establishment (PE) under the India-Korea DTAA, the Tribunal directed the Dispute Resolution Panel (DRP) to re-examine the issue. The Tribunal also instructed the DRP to reconsider the attribution of profits to the alleged PE if found to exist. The Tribunal did not address the levy of interest or the initiation of penalties, focusing primarily on the reassessment and PE issues. The appeals were set aside for the DRP to further investigate and decide accordingly. en-us Mon, 02 Sep 2019 00:00:00 +0530 Fri, 06 Sep 2019 11:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=385464 The Tribunal dismissed the grounds challenging the reassessment proceedings under Section 147 of the Income Tax Act for the years 2004-05 to 2010-11. Regarding the existence of a Permanent Establishment (PE) under the India-Korea DTAA, the Tribunal directed the Dispute Resolution Panel (DRP) to re-examine the issue. The Tribunal also instructed the DRP to reconsider the attribution of profits to the alleged PE if found to exist. The Tribunal did not address the levy of interest or the initiation of penalties, focusing primarily on the reassessment and PE issues. The appeals were set aside for the DRP to further investigate and decide accordingly. Case-Laws Income Tax Mon, 02 Sep 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=385464