Tax Authorities Fail to Investigate Offshore Services, CIT Steps in for Revision u/s 263.

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....Revision u/s 263 - nature/scope of offshore services were not examined - the relief under the provisions of tax treaty has been granted to the Appellant without inquiring into the nature and scope of offshore services. AO has also failed to make necessary enquiry/verification regarding the income attributable to the Project offices in India. In our view, the CIT had jurisdiction to exercise power of revision u/s 263 - AT....