TMI BlogRe-opening of assessment u/s 147 - whether the non-resident entities had Permanent Establishment (“PE”)...Re-opening of assessment u/s 147 - whether the non-resident entities had Permanent Establishment (“PE”) in India and if the PE existed what would be the income attributable to such alleged PE - in any case, transaction has been found to arm’s length then the entire question of PE becomes academic and there is no merit in the re-assessment proceedings initiated u/s 147 of the Act. - AT ..... X X X X Extracts X X X X X X X X Extracts X X X X
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