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of The ITAT allowed the taxpayer's appeal, setting aside the Commissioner's revisional order under section 263 and upholding the taxpayer's claim under section 44B for income from coastal shipping. The Tribunal also accepted the taxpayer's entitlement to exemption under Article 8 of the India-Singapore DTAA in respect of outward freight, concluding that the CIT's exercise of jurisdiction under section 263 was mechanical and without proper application of mind. The ITAT therefore held that such receipts do not accrue or arise in India for the relevant assessment year and directed restoration of the assessment consistent with these conclusions.
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