https://www.taxtmi.com/caselaws?id=790130 Reopening of assessment under the income-tax law turned on whether the recorded reasons disclosed tangible material to form a belief that the non-resident petitioners had a dependent PE or fixed place PE in India for the relevant assessment years. The Delhi High Court held that the reasons did not show such tangible material and, on that basis, sustained challenge to the notices issued under section 148. The Supreme Court condoned the delay and dismissed the Special Leave Petition, finding no good ground to interfere with the High Court's order. en-us Fri, 17 Apr 2026 00:00:00 +0530 Mon, 20 Apr 2026 08:30:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790130 Reopening of assessment under the income-tax law turned on whether the recorded reasons disclosed tangible material to form a belief that the non-resident petitioners had a dependent PE or fixed place PE in India for the relevant assessment years. The Delhi High Court held that the reasons did not show such tangible material and, on that basis, sustained challenge to the notices issued under section 148. The Supreme Court condoned the delay and dismissed the Special Leave Petition, finding no good ground to interfere with the High Court's order. Case-Laws Income Tax Fri, 17 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790130