https://www.taxtmi.com/caselaws?id=800003 Reassessment limitation excludes the period allowed for replying to a notice seeking explanation, including any extension. After that exclusion and the statutory extended period are applied, an order and notice issued within three years require approval from the Commissioner as the specified authority. Separately, an Indian associated enterprise does not create a dependent-agent permanent establishment where the identical business model and facts previously established no such presence. Business profits therefore cannot be attributed to India on a dependent-agent permanent-establishment basis. en-us Mon, 21 Sep 2026 00:00:00 +0530 Wed, 30 Sep 2026 08:41:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800003 Reassessment limitation excludes the period allowed for replying to a notice seeking explanation, including any extension. After that exclusion and the statutory extended period are applied, an order and notice issued within three years require approval from the Commissioner as the specified authority. Separately, an Indian associated enterprise does not create a dependent-agent permanent establishment where the identical business model and facts previously established no such presence. Business profits therefore cannot be attributed to India on a dependent-agent permanent-establishment basis. Case-Laws Income Tax Mon, 21 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800003