https://www.taxtmi.com/highlights?id=55437 Re-opening of assessment u/s 147 - whether the non-resident entities had Permanent Establishment (“PE”) in India and if the PE existed what would be the income attributable to such alleged PE - in any case, transaction has been found to arm’s length then the entire question of PE becomes academic and there is no merit in the re-assessment proceedings initiated u/s 147 of the Act. - AT en-us Sat, 07 Nov 2020 16:59:32 +0530 Sat, 07 Nov 2020 16:59:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=55437 Re-opening of assessment u/s 147 - whether the non-resident entities had Permanent Establishment (“PE”) in India and if the PE existed what would be the income attributable to such alleged PE - in any case, transaction has been found to arm’s length then the entire question of PE becomes academic and there is no merit in the re-assessment proceedings initiated u/s 147 of the Act. - AT Highlights Income Tax Sat, 07 Nov 2020 16:59:32 +0530 https://www.taxtmi.com/highlights?id=55437