https://www.taxtmi.com/caselaws?id=759829 HC upheld reassessment under Section 147/148, finding a prima facie belief of escapement of income because the appellant failed to disclose revenue from sales to Indian customers. The Court rejected challenges to jurisdiction and to reopening, noting prior determinations on Fixed Place PE and DAPE had attained finality and the appellant did not show materially changed facts. The Tribunal's attribution of profits to Indian operations was sustained: the Court held roughly one-quarter of marketing effort occurred in India and directed the AO to attribute 26% of total profit to the PE in India, ordering application of 2.6% on total sales for profit computation. en-us Thu, 19 Sep 2024 00:00:00 +0530 Mon, 01 Sep 2025 11:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759829 HC upheld reassessment under Section 147/148, finding a prima facie belief of escapement of income because the appellant failed to disclose revenue from sales to Indian customers. The Court rejected challenges to jurisdiction and to reopening, noting prior determinations on Fixed Place PE and DAPE had attained finality and the appellant did not show materially changed facts. The Tribunal's attribution of profits to Indian operations was sustained: the Court held roughly one-quarter of marketing effort occurred in India and directed the AO to attribute 26% of total profit to the PE in India, ordering application of 2.6% on total sales for profit computation. Case-Laws Income Tax Thu, 19 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759829