S. 263 CIT can revise AO’s order of taxing receipt as ordinary income instead of taxing it u/s. 44BB

HIGH COURT OF UUTTARAKHAND M-I Overseas Ltd. Versus Director of Income-tax, International Taxation-II IT APPEAL NO. 25 OF 2012 OCTOBER 3, 2012 JUDGMENT Barin Ghosh, CJ. The assessee, appellant herein, though has its situs outside India, but has a permanent establishment in India. It has provided services in India in consideration of payments made to it by its Indian customers. For the assessment year 2006-2007, assessee filed its return of income disclosing therein that it has made taxable income of Rs. 6,18,35,432/-. Notice under Section 143(2) of the Income Tax Act, 1961 (hereinafter referr...