Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Revisional power over an assessment requires the order to be both erroneous and prejudicial to the Revenue; it cannot be used to replace a legally plausible view already taken after inquiry. Here, the Assessing Officer examined alleged bogus purchases and made an addition of 12.5%, so the dispute was only over the quantum and manner of addition, not a lack of inquiry. As no illegality was shown in the assessment view, revision under Section 263 was not available, and the Tribunal's setting aside of the revisional order was upheld.
Revisional power over an assessment requires the order to be both erroneous and prejudicial to the Revenue; it cannot be used to replace a legally plausible view already taken after inquiry. Here, the Assessing Officer examined alleged bogus purchases and made an addition of 12.5%, so the dispute was only over the quantum and manner of addition, not a lack of inquiry. As no illegality was shown in the assessment view, revision under Section 263 was not available, and the Tribunal's setting aside of the revisional order was upheld.
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