TMI Blog2019 (7) TMI 308X X X X Extracts X X X X X X X X Extracts X X X X ..... ainst the Assessee were quashed and the appeal was allowed. The Supreme Court held that the notice for reassessment was based only on the allegations that the Appellant has permanent establishment in India , and that the reopening could not be on such basis once the arm s length procedure had been followed. It must be mentioned at this stage that as far as the impugned order in the present app ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ee on the issue of reopening of the assessment under Section 148 of the Income Tax Act, 1941 ( IT Act ) for the same Assessment Year ( AY ) in respect of which the present appeal arises i.e. AY 2006-07, the Allahabad High Court declined to interfere. Against the said order of the Allahabad High Court, the Assessee went in appeal before the Supreme Court and in Honda Motor Co. Ltd. v Assistant Di ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Revenue is perhaps contemplating filing a curative petition in the Supreme Court and that in any event, the said review petition did not concern AY 2006-07, with which the present appeal is concerned. 5. It must be mentioned at this stage that as far as the impugned order in the present appeal is concerned, the ITAT has gone entirely by the fact that the Supreme Court has allowed the appe ..... X X X X Extracts X X X X X X X X Extracts X X X X
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