Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
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Revisional jurisdiction under section 263 was not available where the assessment in limited scrutiny was completed after the assessee disclosed the survey declaration and responded to section 142(1) notices, and the Assessing Officer considered those materials. Applying Malabar Industrial and Arvind Jewellers, revision lies only when the assessment order is both erroneous and prejudicial to the interests of the Revenue; a mere difference of opinion on the same material is insufficient. On the facts found, no such error was shown, so the Tribunal was right to quash the revisional order and no substantial question of law arose.
Revisional jurisdiction under section 263 was not available where the assessment in limited scrutiny was completed after the assessee disclosed the survey declaration and responded to section 142(1) notices, and the Assessing Officer considered those materials. Applying Malabar Industrial and Arvind Jewellers, revision lies only when the assessment order is both erroneous and prejudicial to the interests of the Revenue; a mere difference of opinion on the same material is insufficient. On the facts found, no such error was shown, so the Tribunal was right to quash the revisional order and no substantial question of law arose.
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