https://www.taxtmi.com/caselaws?id=446519 ITAT Mumbai dismissed the assessee's appeal challenging CIT's revision order u/s 263. The tribunal held that the AO's assessment order was erroneous and prejudicial to revenue interests as it failed to examine foreign payments made directly by Indian Project Owners to Head Office and the nature/scope of offshore services. While TPO accepted domestic payments to Project Offices as arm's length, no inquiry was conducted regarding Head Office payments despite material on record indicating such transactions. The tribunal found CIT had valid jurisdiction under s.263 as AO granted tax treaty relief without proper verification of offshore services and income attribution to Indian Project Offices, triggering Explanation 2 to Section 263. en-us Wed, 28 Jun 2023 00:00:00 +0530 Wed, 06 Dec 2023 08:58:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446519 ITAT Mumbai dismissed the assessee's appeal challenging CIT's revision order u/s 263. The tribunal held that the AO's assessment order was erroneous and prejudicial to revenue interests as it failed to examine foreign payments made directly by Indian Project Owners to Head Office and the nature/scope of offshore services. While TPO accepted domestic payments to Project Offices as arm's length, no inquiry was conducted regarding Head Office payments despite material on record indicating such transactions. The tribunal found CIT had valid jurisdiction under s.263 as AO granted tax treaty relief without proper verification of offshore services and income attribution to Indian Project Offices, triggering Explanation 2 to Section 263. Case-Laws Income Tax Wed, 28 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446519