Revisiting earlier order on merits is beyond the scope & ambit of powers available u/s 254(2)

CIT Vs Reliance Telecom Limited (Supreme Court of India)

Facts- The Assessee entered into Supply Contract dated 15.06.2004 with Ericsson A.B. Assessee filed an application under Section 195(2) of the Act before the AO, to make payment to the non­resident company for purchase of software without TDS. It was contended by the Assessee that it was for the purchase of software and Ericsson A.B. had no permanent establishment in India and in terms of the DTAA between India and Sweden & USA, the amount paid is

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