https://www.taxtmi.com/caselaws?id=769924 The ITAT Jaipur quashed a revision order u/s 263 regarding dividend income taxation under the India-Morocco tax treaty. The AO had conducted scrutiny assessment on 11 points, expressing satisfaction on 10 issues including double taxation relief u/s 90/91, though reasons were not explicitly recorded for each point. The PCIT held the assessment erroneous for not taxing dividend as business income. The ITAT ruled that the AO had applied his mind after verifying assessee's information against ITR and TAR. Since the PCIT merely expressed a different opinion on the same material rather than identifying genuine errors, s.263 revision was not justified. The tribunal noted a similar issue for AY 2018-19 was previously decided in assessee's favor by coordinate bench. en-us Mon, 28 Apr 2025 00:00:00 +0530 Sat, 03 May 2025 08:34:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769924 The ITAT Jaipur quashed a revision order u/s 263 regarding dividend income taxation under the India-Morocco tax treaty. The AO had conducted scrutiny assessment on 11 points, expressing satisfaction on 10 issues including double taxation relief u/s 90/91, though reasons were not explicitly recorded for each point. The PCIT held the assessment erroneous for not taxing dividend as business income. The ITAT ruled that the AO had applied his mind after verifying assessee's information against ITR and TAR. Since the PCIT merely expressed a different opinion on the same material rather than identifying genuine errors, s.263 revision was not justified. The tribunal noted a similar issue for AY 2018-19 was previously decided in assessee's favor by coordinate bench. Case-Laws Income Tax Mon, 28 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769924