https://www.taxtmi.com/highlights?id=104352 Reassessment limitation must exclude the time, including any extension, allowed for a response to a notice under section 148A(b). Following that exclusion, reassessment steps issued within three years remain within the applicable limitation framework, and the Commissioner is the competent specified authority under section 151(i); approval from the Principal Chief Commissioner is unnecessary. An Indian associated enterprise providing support services does not constitute a dependent agent permanent establishment where its business model and material facts correspond to an earlier year in which no such PE existed. Consequently, no question of profit attribution arises. en-us Wed, 30 Sep 2026 08:41:54 +0530 Wed, 30 Sep 2026 08:41:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=104352 Reassessment limitation must exclude the time, including any extension, allowed for a response to a notice under section 148A(b). Following that exclusion, reassessment steps issued within three years remain within the applicable limitation framework, and the Commissioner is the competent specified authority under section 151(i); approval from the Principal Chief Commissioner is unnecessary. An Indian associated enterprise providing support services does not constitute a dependent agent permanent establishment where its business model and material facts correspond to an earlier year in which no such PE existed. Consequently, no question of profit attribution arises. Highlights Income Tax Wed, 30 Sep 2026 08:41:54 +0530 https://www.taxtmi.com/highlights?id=104352