https://www.taxtmi.com/caselaws?id=435135 Revision under section 263 cannot enlarge a limited-scrutiny assessment beyond the issues assigned for examination where the Assessing Officer examined those issues, obtained transfer-pricing verification, and completed the assessment on that basis. Revisionary intervention requires a demonstrated failure concerning the limited-scrutiny mandate and cannot indirectly introduce prohibited enquiries. Treaty protection under the India-Singapore DTAA remains available where a valid Tax Residency Certificate and international shipping operations support residence and eligibility, absent corroborative material establishing conduit status or lack of commercial rationale. Freight from transporting goods is not royalty merely because vessels are used in shipping operations; recharacterisation requires an evidentiary basis. 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 Revision under section 263 cannot enlarge a limited-scrutiny assessment beyond the issues assigned for examination where the Assessing Officer examined those issues, obtained transfer-pricing verification, and completed the assessment on that basis. Revisionary intervention requires a demonstrated failure concerning the limited-scrutiny mandate and cannot indirectly introduce prohibited enquiries. Treaty protection under the India-Singapore DTAA remains available where a valid Tax Residency Certificate and international shipping operations support residence and eligibility, absent corroborative material establishing conduit status or lack of commercial rationale. Freight from transporting goods is not royalty merely because vessels are used in shipping operations; recharacterisation requires an evidentiary basis. Case-Laws Income Tax Thu, 09 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=435135