https://www.taxtmi.com/caselaws?id=155019 The Tribunal upheld the Director of Income-tax's order under section 263, finding the Assessing Officer's assessment erroneous and prejudicial to revenue due to lack of proper enquiry and application of mind. The Tribunal determined that the income received was taxable in India as royalty under the treaty, emphasizing the failure to establish the absence of a Permanent Establishment in India. Consequently, the Tribunal dismissed the assessee's appeal, directing a fresh assessment with thorough examination and enquiry. en-us Tue, 20 Sep 2011 00:00:00 +0530 Sat, 31 Aug 2013 11:57:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=155019 The Tribunal upheld the Director of Income-tax's order under section 263, finding the Assessing Officer's assessment erroneous and prejudicial to revenue due to lack of proper enquiry and application of mind. The Tribunal determined that the income received was taxable in India as royalty under the treaty, emphasizing the failure to establish the absence of a Permanent Establishment in India. Consequently, the Tribunal dismissed the assessee's appeal, directing a fresh assessment with thorough examination and enquiry. Case-Laws Income Tax Tue, 20 Sep 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=155019