https://www.taxtmi.com/caselaws?id=795535 Revision proceedings under section 263 must comply with audi alteram partem where allegations of treaty shopping or conduit arrangements are raised. DTAA benefits, permanent establishment status, and characterisation of receipts as fees for technical services depend on factual determination, including whether the taxpayer is a conduit arrangement. The Commissioner's revision order was set aside because the taxpayer had not been given an opportunity to answer the conduit and treaty-shopping allegation. The Special Leave Petition was dismissed due to inordinate delay in filing. 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 must comply with audi alteram partem where allegations of treaty shopping or conduit arrangements are raised. DTAA benefits, permanent establishment status, and characterisation of receipts as fees for technical services depend on factual determination, including whether the taxpayer is a conduit arrangement. The Commissioner's revision order was set aside because the taxpayer had not been given an opportunity to answer the conduit and treaty-shopping allegation. The Special Leave Petition was dismissed due to inordinate delay in filing. Case-Laws Income Tax Mon, 20 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795535