https://www.taxtmi.com/caselaws?id=457327 Revision under section 263 was unsustainable where the Assessing Officer had made specific enquiries, examined the contract and supporting records, and accepted the assessee's position under Article 5(5) of the India-Singapore treaty that services in India were rendered for 102 days, below the treaty threshold. The special treaty rule for services connected with mineral oil exploration, exploitation or extraction prevails over the general fixed-place permanent establishment rule in Article 5(1). Since the assessment was completed on a plausible view after due enquiry, it could not be treated as erroneous and prejudicial to the Revenue merely because the Commissioner preferred a different interpretation of the general provision. en-us Mon, 20 Jan 2020 00:00:00 +0530 Mon, 16 Sep 2024 20:01:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=457327 Revision under section 263 was unsustainable where the Assessing Officer had made specific enquiries, examined the contract and supporting records, and accepted the assessee's position under Article 5(5) of the India-Singapore treaty that services in India were rendered for 102 days, below the treaty threshold. The special treaty rule for services connected with mineral oil exploration, exploitation or extraction prevails over the general fixed-place permanent establishment rule in Article 5(1). Since the assessment was completed on a plausible view after due enquiry, it could not be treated as erroneous and prejudicial to the Revenue merely because the Commissioner preferred a different interpretation of the general provision. Case-Laws Income Tax Mon, 20 Jan 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=457327