https://www.taxtmi.com/caselaws?id=798101 Section 263 revision is barred where the revisionary order is passed after the two-year limitation period running from the end of the financial year in which the assessment order was made. The revision also fails where the assessment had examined software arrangements, copyright rights, treaty treatment and relevant Supreme Court precedent before accepting that software-related receipts were not royalty. As no assessment error prejudicial to Revenue was established, the revisionary order was quashed and the original assessment remained undisturbed. en-us Mon, 31 Aug 2026 00:00:00 +0530 Wed, 02 Sep 2026 08:30:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798101 Section 263 revision is barred where the revisionary order is passed after the two-year limitation period running from the end of the financial year in which the assessment order was made. The revision also fails where the assessment had examined software arrangements, copyright rights, treaty treatment and relevant Supreme Court precedent before accepting that software-related receipts were not royalty. As no assessment error prejudicial to Revenue was established, the revisionary order was quashed and the original assessment remained undisturbed. Case-Laws Income Tax Mon, 31 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798101