https://www.taxtmi.com/caselaws?id=448149 Tangible material from the survey, including impounded documents and employee statements, was treated as sufficient to support a prima facie belief of escapement of income, so the reopening was sustained despite the challenge on notice and nexus grounds. The liaison office was held to constitute a permanent establishment under Article 5 of the India-Germany DTAA because its functions went beyond preparatory or auxiliary activity and included commercially substantive steps in reprinting and sales coordination. Income attribution was confined to EPZ sales linked to that activity, while direct overseas sales were excluded; the profit rate was reduced and recomputation directed on a more reasonable basis with appropriate deductions. en-us Thu, 04 Jan 2024 00:00:00 +0530 Wed, 18 Dec 2024 15:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448149 Tangible material from the survey, including impounded documents and employee statements, was treated as sufficient to support a prima facie belief of escapement of income, so the reopening was sustained despite the challenge on notice and nexus grounds. The liaison office was held to constitute a permanent establishment under Article 5 of the India-Germany DTAA because its functions went beyond preparatory or auxiliary activity and included commercially substantive steps in reprinting and sales coordination. Income attribution was confined to EPZ sales linked to that activity, while direct overseas sales were excluded; the profit rate was reduced and recomputation directed on a more reasonable basis with appropriate deductions. Case-Laws Income Tax Thu, 04 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448149