Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Revision under section 263 was held unsustainable because the Assessing Officer had properly examined the relevant material, accepted the assessee's project completion method, and adopted one permissible view on the taxability of on-money from the Spring-II project. The Court reiterated that revision is available only when the assessment order is both erroneous and prejudicial to the interests of the Revenue; a mere difference of opinion cannot justify interference where enquiries were made and the view taken was plausible. No material showed that the amount was taxable in the relevant assessment year, so the appeal was dismissed and no substantial question of law arose.
Revision under section 263 was held unsustainable because the Assessing Officer had properly examined the relevant material, accepted the assessee's project completion method, and adopted one permissible view on the taxability of on-money from the Spring-II project. The Court reiterated that revision is available only when the assessment order is both erroneous and prejudicial to the interests of the Revenue; a mere difference of opinion cannot justify interference where enquiries were made and the view taken was plausible. No material showed that the amount was taxable in the relevant assessment year, so the appeal was dismissed and no substantial question of law arose.
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