Reassessment limitation excludes section 148A response time; Indian support-services affiliate does not create a dependent agent PE.

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....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.....