https://www.taxtmi.com/caselaws?id=218794 Revisional jurisdiction under section 263 could not be invoked where the Assessing Officer had called for the agreements, examined the assessee's explanation, and adopted a plausible view that the manpower supply receipts were not fees for technical services or included services. Revision requires the assessment order to be both erroneous and prejudicial to the interests of the Revenue, and that test was not met because the issue had been examined on record. An earlier Tribunal view on the same arrangement also supported the conclusion that the service was akin to recruitment or placement and did not make available technical knowledge, skill, plan or design. en-us Fri, 27 Jul 2012 00:00:00 +0530 Mon, 15 Oct 2012 12:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=218794 Revisional jurisdiction under section 263 could not be invoked where the Assessing Officer had called for the agreements, examined the assessee's explanation, and adopted a plausible view that the manpower supply receipts were not fees for technical services or included services. Revision requires the assessment order to be both erroneous and prejudicial to the interests of the Revenue, and that test was not met because the issue had been examined on record. An earlier Tribunal view on the same arrangement also supported the conclusion that the service was akin to recruitment or placement and did not make available technical knowledge, skill, plan or design. Case-Laws Income Tax Fri, 27 Jul 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=218794