https://www.taxtmi.com/caselaws?id=790728 Reopening under Sections 147/148 requires tangible material supporting a valid reason to believe that income has escaped assessment. On the recorded reasons, the High Court found no sufficient material to infer a dependent agent permanent establishment or fixed place permanent establishment in India for the relevant years, so the statutory threshold for reopening was not met and the notices were unsustainable. The Supreme Court saw no reason to interfere with that order and dismissed the special leave petitions. en-us Mon, 27 Apr 2026 00:00:00 +0530 Tue, 28 Apr 2026 12:17:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790728 Reopening under Sections 147/148 requires tangible material supporting a valid reason to believe that income has escaped assessment. On the recorded reasons, the High Court found no sufficient material to infer a dependent agent permanent establishment or fixed place permanent establishment in India for the relevant years, so the statutory threshold for reopening was not met and the notices were unsustainable. The Supreme Court saw no reason to interfere with that order and dismissed the special leave petitions. Case-Laws Income Tax Mon, 27 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790728