https://www.taxtmi.com/caselaws?id=781328 ITAT MUMBAI (AT) quashed the PCIT's revision under s.263 overturning the AO's deletion of a disallowance relating to foreign professional fees where TDS under s.195 was not deducted. The Tribunal held the AO had conducted enquiries and correctly found recipients taxable in India only if covered by treaty provisions (Article 7/14/15) via a PE or fixed base, which was absent. PCIT had not recorded reasons nor carried out independent verification before setting aside the assessment; consequently the s.263 order was unsustainable and was quashed, relief allowed to the assessee. en-us Thu, 28 Aug 2025 00:00:00 +0530 Wed, 12 Nov 2025 15:40:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781328 ITAT MUMBAI (AT) quashed the PCIT's revision under s.263 overturning the AO's deletion of a disallowance relating to foreign professional fees where TDS under s.195 was not deducted. The Tribunal held the AO had conducted enquiries and correctly found recipients taxable in India only if covered by treaty provisions (Article 7/14/15) via a PE or fixed base, which was absent. PCIT had not recorded reasons nor carried out independent verification before setting aside the assessment; consequently the s.263 order was unsustainable and was quashed, relief allowed to the assessee. Case-Laws Income Tax Thu, 28 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781328