https://www.taxtmi.com/highlights?id=103855 Section 263 revision was sustained for fresh examination of interest capitalisation because the actual use of external commercial borrowings for working capital was not demonstrated and the Assessing Officer had made no enquiry; a board resolution stating the borrowing purpose was insufficient. Revision could not, however, reopen matters already examined or direct unfocused verification. Directions concerning tax deduction on interest paid to Government authorities were deleted as they amounted to a fishing or roving enquiry without an identified assessment error. Re-examination of miscellaneous expenditure and service-provider charges was also deleted because the Assessing Officer had examined the evidence and adopted a plausible view, including on the treaty's make available clause. en-us Thu, 17 Sep 2026 07:52:26 +0530 Thu, 17 Sep 2026 07:52:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=103855 Section 263 revision was sustained for fresh examination of interest capitalisation because the actual use of external commercial borrowings for working capital was not demonstrated and the Assessing Officer had made no enquiry; a board resolution stating the borrowing purpose was insufficient. Revision could not, however, reopen matters already examined or direct unfocused verification. Directions concerning tax deduction on interest paid to Government authorities were deleted as they amounted to a fishing or roving enquiry without an identified assessment error. Re-examination of miscellaneous expenditure and service-provider charges was also deleted because the Assessing Officer had examined the evidence and adopted a plausible view, including on the treaty's make available clause. Highlights Income Tax Thu, 17 Sep 2026 07:52:26 +0530 https://www.taxtmi.com/highlights?id=103855