https://www.taxtmi.com/highlights?id=59818 Reopening of assessment u/s 147 - Income accrued in India - It is also not understood as to how the appellant-Revenue can contend that the respondent-assessee does not have PE in India for the purpose of 201 proceedings in the case of LGEIL but would have a PE as far as its own taxability is concerned for the same Assessment Year. - Moreover, in view of the decision of the Apex Court, the proceedings initiated by the appellant-Revenue has become infructuous and accordingly ex debito justitiae - HC en-us Fri, 24 Sep 2021 13:20:18 +0530 Fri, 24 Sep 2021 13:20:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=59818 Reopening of assessment u/s 147 - Income accrued in India - It is also not understood as to how the appellant-Revenue can contend that the respondent-assessee does not have PE in India for the purpose of 201 proceedings in the case of LGEIL but would have a PE as far as its own taxability is concerned for the same Assessment Year. - Moreover, in view of the decision of the Apex Court, the proceedings initiated by the appellant-Revenue has become infructuous and accordingly ex debito justitiae - HC Highlights Income Tax Fri, 24 Sep 2021 13:20:18 +0530 https://www.taxtmi.com/highlights?id=59818