https://www.taxtmi.com/caselaws?id=267997 Review under Section 260A of the Income-tax Act is confined to an apparent error on the face of the record. In this matter, the core dispute concerned permanent establishment under treaty provisions, and the material showed that the appellate issue had been decided mainly with reference to Article 5(2)(j). There was no concluded basis to treat Article 5(2)(a), (b) and (c) as separately formulated and decided on the facts. The Court found no apparent error in the earlier judgment and, on that basis, the review petitions were not maintainable on merits. en-us Mon, 14 Sep 2015 00:00:00 +0530 Wed, 18 Nov 2015 09:37:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=267997 Review under Section 260A of the Income-tax Act is confined to an apparent error on the face of the record. In this matter, the core dispute concerned permanent establishment under treaty provisions, and the material showed that the appellate issue had been decided mainly with reference to Article 5(2)(j). There was no concluded basis to treat Article 5(2)(a), (b) and (c) as separately formulated and decided on the facts. The Court found no apparent error in the earlier judgment and, on that basis, the review petitions were not maintainable on merits. Case-Laws Income Tax Mon, 14 Sep 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=267997