https://www.taxtmi.com/caselaws?id=435135 An assessment completed under limited scrutiny cannot be revised under section 263 on matters outside the specific issues assigned for examination, and revision is unsustainable where the Assessing Officer has applied the prescribed scrutiny and enquiry to those limited issues. The article also notes that a valid Tax Residency Certificate supported treaty protection under the India-Singapore DTAA, and the assessee's shipping receipts were transportation income, not royalty, because they were not consideration for the use of vessels as equipment. On these facts, the revisional authority's contrary view lacked evidentiary support and the original assessment was restored. en-us Thu, 09 Mar 2023 00:00:00 +0530 Mon, 13 Mar 2023 08:41:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=435135 An assessment completed under limited scrutiny cannot be revised under section 263 on matters outside the specific issues assigned for examination, and revision is unsustainable where the Assessing Officer has applied the prescribed scrutiny and enquiry to those limited issues. The article also notes that a valid Tax Residency Certificate supported treaty protection under the India-Singapore DTAA, and the assessee's shipping receipts were transportation income, not royalty, because they were not consideration for the use of vessels as equipment. On these facts, the revisional authority's contrary view lacked evidentiary support and the original assessment was restored. Case-Laws Income Tax Thu, 09 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=435135