https://www.taxtmi.com/caselaws?id=753670 Where an assessee raised a jurisdictional objection that software-sale receipts were not royalty and that no permanent establishment existed in India, the reopening authority was required to adjudicate those objections at the section 148A(d) stage itself. By deferring both issues for later verification without meaningful engagement, the authority failed to form the necessary satisfaction before assuming jurisdiction. The reassessment initiation was therefore held unsustainable and was quashed. en-us Mon, 27 May 2024 00:00:00 +0530 Thu, 06 Jun 2024 18:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753670 Where an assessee raised a jurisdictional objection that software-sale receipts were not royalty and that no permanent establishment existed in India, the reopening authority was required to adjudicate those objections at the section 148A(d) stage itself. By deferring both issues for later verification without meaningful engagement, the authority failed to form the necessary satisfaction before assuming jurisdiction. The reassessment initiation was therefore held unsustainable and was quashed. Case-Laws Income Tax Mon, 27 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753670