https://www.taxtmi.com/caselaws?id=58494 Reopening under section 148 was upheld because the assessee had not disclosed the primary material agreement itself, and a passing reference in the return and related service agreement was insufficient to satisfy full and true disclosure. The lump sum technical know-how fee was held not taxable in India in part, as the know-how was supplied outside India and the Indian activities were only incidental or protective, so no business connection or income attribution arose from them. Service-agreement income was sustained because the services were to be performed in India and the assessee did not prove deductible expenses. No further relief was allowed for professional fees, as the existing apportionment was considered reasonable on the record. en-us Fri, 20 Dec 1985 00:00:00 +0530 Mon, 20 Dec 2010 12:23:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=58494 Reopening under section 148 was upheld because the assessee had not disclosed the primary material agreement itself, and a passing reference in the return and related service agreement was insufficient to satisfy full and true disclosure. The lump sum technical know-how fee was held not taxable in India in part, as the know-how was supplied outside India and the Indian activities were only incidental or protective, so no business connection or income attribution arose from them. Service-agreement income was sustained because the services were to be performed in India and the assessee did not prove deductible expenses. No further relief was allowed for professional fees, as the existing apportionment was considered reasonable on the record. Case-Laws Income Tax Fri, 20 Dec 1985 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=58494