https://www.taxtmi.com/caselaws?id=325187 Section 263 revision was held unsustainable where the final order travelled beyond the show-cause notice and decided issues not put to the assessee, as effective opportunity is essential to revisional jurisdiction. The Assessing Officer's allowance of credit for deemed dividend tax under the India-Oman DTAA was also upheld because it was a plausible view taken after enquiry and in line with the consistent position accepted in earlier years; revision cannot substitute a different interpretation. The direction to tax undistributed branch profit was rejected because the amount was only an accounting entry and did not represent real income accrued or received. The assessment revisions were quashed. en-us Wed, 09 Mar 2016 00:00:00 +0530 Sat, 12 Mar 2016 09:13:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=325187 Section 263 revision was held unsustainable where the final order travelled beyond the show-cause notice and decided issues not put to the assessee, as effective opportunity is essential to revisional jurisdiction. The Assessing Officer's allowance of credit for deemed dividend tax under the India-Oman DTAA was also upheld because it was a plausible view taken after enquiry and in line with the consistent position accepted in earlier years; revision cannot substitute a different interpretation. The direction to tax undistributed branch profit was rejected because the amount was only an accounting entry and did not represent real income accrued or received. The assessment revisions were quashed. Case-Laws Income Tax Wed, 09 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=325187