https://www.taxtmi.com/caselaws?id=64363 Revision under section 263 applies where an assessment accepts an income computation without genuine inquiry into its basis, allowing unsupported deductions contrary to the applicable treaty method requiring deduction of actual permanent-establishment expenses. Such failure of inquiry and application of mind renders the assessment erroneous and prejudicial to Revenue, permitting fresh computation. Consistency with an approach accepted in earlier years cannot preserve a method that conflicts with the governing legal framework, and an Assessing Officer's view is not a permissible view where it lacks legal and factual support. en-us Thu, 20 Nov 2008 00:00:00 +0530 Mon, 06 Aug 2012 12:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=64363 Revision under section 263 applies where an assessment accepts an income computation without genuine inquiry into its basis, allowing unsupported deductions contrary to the applicable treaty method requiring deduction of actual permanent-establishment expenses. Such failure of inquiry and application of mind renders the assessment erroneous and prejudicial to Revenue, permitting fresh computation. Consistency with an approach accepted in earlier years cannot preserve a method that conflicts with the governing legal framework, and an Assessing Officer's view is not a permissible view where it lacks legal and factual support. Case-Laws Income Tax Thu, 20 Nov 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=64363