https://www.taxtmi.com/highlights?id=94069 The ITAT held that the reassessment proceedings initiated u/s 147 were void ab initio for want of jurisdiction: the AO failed to record cogent reasons or identify tangible material establishing escapement of income before issuing notice, despite knowledge that the assessee was a non-resident foreign company, a TRC holder and SEBI-FPI investor in NCDs whose sole Indian receipts were interest subjected to TDS u/s 194LD. Absent findings of a PE in India or applicability of POEM/s 6(3), there was no obligation to file a return u/s 139(1), and DTAA protections applied. Consequently the ITAT allowed the assessee's grounds and set aside the reassessment initiation. en-us Tue, 11 Nov 2025 08:20:20 +0530 Tue, 11 Nov 2025 08:20:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=94069 The ITAT held that the reassessment proceedings initiated u/s 147 were void ab initio for want of jurisdiction: the AO failed to record cogent reasons or identify tangible material establishing escapement of income before issuing notice, despite knowledge that the assessee was a non-resident foreign company, a TRC holder and SEBI-FPI investor in NCDs whose sole Indian receipts were interest subjected to TDS u/s 194LD. Absent findings of a PE in India or applicability of POEM/s 6(3), there was no obligation to file a return u/s 139(1), and DTAA protections applied. Consequently the ITAT allowed the assessee's grounds and set aside the reassessment initiation. Highlights Income Tax Tue, 11 Nov 2025 08:20:20 +0530 https://www.taxtmi.com/highlights?id=94069