M/s. Atomstroyexport C/o Nuclear Power Corpn. of India Ltd. Versus The Dy. Director of Income- tax (International Taxation) - Income Tax - ITAT MUMBAI - Tri - Validity of reopening of assessment u/s 147 - Held that - The assessment was reopened on the reasons recorded in the A.Y. 2005-06 that receipts in pursuance of offshore services contract are in the nature of royalties and in pursuance to the contract for deputation of specialists and offshore training contract are in the nature of fees for................................... Income Tax - Case Laws
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