https://www.taxtmi.com/caselaws?id=306246 The Tribunal upheld the reopening of the assessment for AY 2006-07 under Section 143(3) read with Section 148 of the Income Tax Act, citing the validity of the notice under Section 148. However, the assessment of income on an accrual basis was not justified, and taxability issues related to Permanent Establishment, commission payments, and basis of taxation were decided in favor of the assessee. For AY 2007-08, the appeal was fully allowed as there was no reopening, with the Tribunal's decision rendered on 15/02/2021. 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 The Tribunal upheld the reopening of the assessment for AY 2006-07 under Section 143(3) read with Section 148 of the Income Tax Act, citing the validity of the notice under Section 148. However, the assessment of income on an accrual basis was not justified, and taxability issues related to Permanent Establishment, commission payments, and basis of taxation were decided in favor of the assessee. For AY 2007-08, the appeal was fully allowed as there was no reopening, with the Tribunal's decision rendered on 15/02/2021. Case-Laws Income Tax Mon, 15 Feb 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306246