https://www.taxtmi.com/caselaws?id=342065 A revisional order under section 263 was held unsustainable where it went beyond the show-cause notice and sought to disturb an assessment completed after specific enquiries; revision cannot rest on a mere change of opinion when the Assessing Officer had adopted a plausible view after hearing the assessee. On treaty relief, dividend income received in Oman qualified for deemed tax credit under Article 25(4) of the India-Oman DTAA read with section 90 because the Omani exemption was shown to be a tax incentive linked to economic development, and the competent foreign clarification plus consistent prior treatment supported that view. The revision failed and treaty credit was upheld. en-us Fri, 21 Apr 2017 00:00:00 +0530 Wed, 28 Jan 2026 16:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=342065 A revisional order under section 263 was held unsustainable where it went beyond the show-cause notice and sought to disturb an assessment completed after specific enquiries; revision cannot rest on a mere change of opinion when the Assessing Officer had adopted a plausible view after hearing the assessee. On treaty relief, dividend income received in Oman qualified for deemed tax credit under Article 25(4) of the India-Oman DTAA read with section 90 because the Omani exemption was shown to be a tax incentive linked to economic development, and the competent foreign clarification plus consistent prior treatment supported that view. The revision failed and treaty credit was upheld. Case-Laws Income Tax Fri, 21 Apr 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=342065