https://www.taxtmi.com/caselaws?id=306246 Where a return is processed only under section 143(1), reassessment under section 148 can be initiated if the Assessing Officer forms the requisite belief on available information, and the reopening is not jurisdictionally invalid. In the treaty attribution analysis, the Indian agent was treated as a dependent agent permanent establishment, but the decisive factor was that the agent's remuneration for India-related functions was accepted as arm's length. On that basis, no further profits were attributable to the foreign enterprise merely because Indian advertisement receipts were routed through the agent, and the additional grounds on accrual versus cash basis were also answered against further taxation. en-us Mon, 15 Feb 2021 00:00:00 +0530 Thu, 19 Jan 2023 08:36:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306246 Where a return is processed only under section 143(1), reassessment under section 148 can be initiated if the Assessing Officer forms the requisite belief on available information, and the reopening is not jurisdictionally invalid. In the treaty attribution analysis, the Indian agent was treated as a dependent agent permanent establishment, but the decisive factor was that the agent's remuneration for India-related functions was accepted as arm's length. On that basis, no further profits were attributable to the foreign enterprise merely because Indian advertisement receipts were routed through the agent, and the additional grounds on accrual versus cash basis were also answered against further taxation. Case-Laws Income Tax Mon, 15 Feb 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306246