https://www.taxtmi.com/caselaws?id=400454 Where international transactions were accepted at arm's length, the Tribunal held that reassessment based on an alleged permanent establishment could not be sustained because no further profit could be attributed once the arm's length principle was satisfied, and the reopening lacked foundation when the PE basis failed. It also held that a curable defect in the memorandum of appeal regarding the PAN could not justify summary rejection of the assessee's appeals, since the statutory right of appeal must be construed reasonably and liberally. The reassessment proceedings and the technical dismissal were both set aside, and the assessee succeeded. en-us Tue, 20 Oct 2020 00:00:00 +0530 Sat, 07 Nov 2020 10:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=400454 Where international transactions were accepted at arm's length, the Tribunal held that reassessment based on an alleged permanent establishment could not be sustained because no further profit could be attributed once the arm's length principle was satisfied, and the reopening lacked foundation when the PE basis failed. It also held that a curable defect in the memorandum of appeal regarding the PAN could not justify summary rejection of the assessee's appeals, since the statutory right of appeal must be construed reasonably and liberally. The reassessment proceedings and the technical dismissal were both set aside, and the assessee succeeded. Case-Laws Income Tax Tue, 20 Oct 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=400454