https://www.taxtmi.com/caselaws?id=787161 Revisional jurisdiction could not be invoked under section 263 because the assessment record showed detailed enquiry by the Assessing Officer, and an order is not erroneous merely for lacking elaborate reasoning; section 263 requires both error and prejudice to Revenue. Long-term capital gains from sale of listed shares by a Mauritius-resident foreign company with no permanent establishment in India remained exempt, as the gains fell within the statutory treaty-protected framework and section 115JB did not apply to such a foreign company. Unsubstantiated allegations of treaty shopping and conduit arrangement were rejected, and the assessee was held entitled to the treaty and statutory benefit. en-us Wed, 25 Feb 2026 00:00:00 +0530 Fri, 27 Feb 2026 08:36:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787161 Revisional jurisdiction could not be invoked under section 263 because the assessment record showed detailed enquiry by the Assessing Officer, and an order is not erroneous merely for lacking elaborate reasoning; section 263 requires both error and prejudice to Revenue. Long-term capital gains from sale of listed shares by a Mauritius-resident foreign company with no permanent establishment in India remained exempt, as the gains fell within the statutory treaty-protected framework and section 115JB did not apply to such a foreign company. Unsubstantiated allegations of treaty shopping and conduit arrangement were rejected, and the assessee was held entitled to the treaty and statutory benefit. Case-Laws Income Tax Wed, 25 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787161