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No reassessment as royalty payment to US Co. duly disclosed & offered to tax by Indian Co. in representative capacity

June 9, 2020[2020] 116 887 (Delhi - Trib.)

INTERNATIONAL TAXATION : Where royalty payment to assessee US company was duly disclosed and offered to tax in return of income filed by Indian company in capacity of representative assessee, reassessment of assessee could not be initiated on ground that assessee had not offered tax on royalty

INTERNATIONAL TAXATION: Where during assessment, assessee US company submitted that it did not have any activity that would constitute PE and furnished agreements with Indian company and assessee's contention was duly accepted by Assessing Officer, re-opening of concluded assessment on ground that assessee had a PE in India was unjustified

INTERNATIONAL TAXATION: Where assessee-US company furnished copies of agreement relating to secondment of employees during assessment which was examined by Assessing Officer and he held that there was no fixed place PE, reassessment on ground that by secondment constituted a fixed place of business of assessee was unjustified

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