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2012 (8) TMI 383 - HC - Income TaxReopening of assessment – income escaped assessment - Assessee, a non-resident, was operating in India through its liaison office and project office - it was found that assessee did not include sales to DMRC effected through project office which amount represented milestone payments received abroad in foreign currency and same was not offered to tax in India as income of project office – Held that:- Even if the materials/evidence was not enclosed with the return, full and true details/material was disclosed during the course of the original proceedings - project office was a permanent establishment - conclusion drawn by the Assessing Officer cannot be attributed to the failure of the petitioner to disclose fully and truly all the material facts. No new material fact or particulars have come to the notice/knowledge of the Assessing Officer - re-assessment order quashed
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