Reassessment proceedings was held to be valid by High Court .Subsequent finding of DRP that there was no permanent of assessee in India , AO has dropped reasssement proceedings. Accordingly the order passed by High Court up holding validity of proceedings was set aside and appeals are allowed . (AY. 2004-2005)
Principal Officer, L.G. Electronics Inc. v. ADIT (IT) ( 2018) 255 Taxman 77/168 DTR 426 / 304 CTR 109 / 101 CCH 273 (SC) Editorial: Order in Principal Officer, L.G. Electronics Inc. v. ADIT (IT)(2014) 368 ITR 401/226 Taxmann 204/271 CTR 663 (All.)(HC) is set aside.
S.147 : Reassessment – Notice – Non-resident – Permanent-establishment – Tax deduction at source – Survey –Reassessment proceedings was held to be valid by High Court -Subsequent finding of DRP that there was no permanent of assessee in India , AO has dropped reasssement proceedings- Order passed by High Court up holding validity of proceedings was set aside- DTAA–India–Korea. [S.148, Art. 5 ]