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2012 (10) TMI 473 - AT - Income TaxFees for Market Development Overseas - Revision u/s 263 - Held that:- Giving marketing services outside India, even if we consider it as technical services, nothing was made available to the assessee in the nature of any technical knowledge, experience, skill know-how or processes. There was no development or transfer of any technical plan or technical design. CIT in his order under Section 263 has not pointed out any sort of similar transfer or any sort of technical knowledge being made available to the assessee. Twin conditions required for invoking Section 263, that there should be an error in the order of Assessing Officer and such error should be prejudicial to the interests of Revenue, have not been satisfied. - in favour of Assessee.
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