https://www.taxtmi.com/caselaws?id=464489 HC held that notices under Section 148A(b) were deficient for failing to specify the nature of the remittance or the specific head of income purportedly chargeable to tax, and that a bare assertion that a remittance "constitutes income" is insufficient to sustain reopening. The petitioner's contentions - including reliance on Supreme Court precedent and absence of a PE in India - warranted further examination. The court directed further consideration and listed the matter for hearing on 18.08.2023. en-us Thu, 22 Dec 2022 00:00:00 +0530 Thu, 30 Oct 2025 16:52:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464489 HC held that notices under Section 148A(b) were deficient for failing to specify the nature of the remittance or the specific head of income purportedly chargeable to tax, and that a bare assertion that a remittance "constitutes income" is insufficient to sustain reopening. The petitioner's contentions - including reliance on Supreme Court precedent and absence of a PE in India - warranted further examination. The court directed further consideration and listed the matter for hearing on 18.08.2023. Case-Laws Income Tax Thu, 22 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464489