https://www.taxtmi.com/caselaws?id=795535 Revision proceedings under section 263 require an effective opportunity to answer allegations of treaty shopping or conduit arrangements. The note addresses whether DTAA benefits, permanent establishment status and treatment as fees for technical services depend on factual determination. It records that the High Court upheld the ITAT's setting aside of the revision order because the assessee was not heard on the conduit allegation, while the SLP was dismissed for inordinate filing delay. en-us Mon, 20 Jul 2026 00:00:00 +0530 Thu, 23 Jul 2026 08:42:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795535 Revision proceedings under section 263 require an effective opportunity to answer allegations of treaty shopping or conduit arrangements. The note addresses whether DTAA benefits, permanent establishment status and treatment as fees for technical services depend on factual determination. It records that the High Court upheld the ITAT's setting aside of the revision order because the assessee was not heard on the conduit allegation, while the SLP was dismissed for inordinate filing delay. Case-Laws Income Tax Mon, 20 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795535