https://www.taxtmi.com/caselaws?id=440864 Revision under section 263 could not be sustained where the assessment record showed inquiry into the contracts, receipts, associated enterprise details and work executed, and the officer had considered the material before allowing the offshore supply receipts as separate supplies made from outside India with title passing abroad. The issues of taxability, composite contract treatment and permanent establishment were treated as debatable, while the surety commission had already been offered to tax and no material showed the transfer pricing transaction was not at arm's length. Fresh grounds not included in the revision notices could not support revision, and parallel proceedings on the same offshore supply issue before the AAR further undermined jurisdiction. The assessment was restored. en-us Fri, 24 Mar 2023 00:00:00 +0530 Fri, 28 Jul 2023 15:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=440864 Revision under section 263 could not be sustained where the assessment record showed inquiry into the contracts, receipts, associated enterprise details and work executed, and the officer had considered the material before allowing the offshore supply receipts as separate supplies made from outside India with title passing abroad. The issues of taxability, composite contract treatment and permanent establishment were treated as debatable, while the surety commission had already been offered to tax and no material showed the transfer pricing transaction was not at arm's length. Fresh grounds not included in the revision notices could not support revision, and parallel proceedings on the same offshore supply issue before the AAR further undermined jurisdiction. The assessment was restored. Case-Laws Income Tax Fri, 24 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=440864