Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Revision under section 263 requires the assessment order to be both erroneous and prejudicial to the interests of the Revenue. The distinction between lack of inquiry and inadequate inquiry is material: where the Assessing Officer has examined relevant expenses, related-party payments, GST-exempt services, financial records, returns, GST details, TDS particulars and supplier-level material, revision cannot be based merely on a view that further verification was desirable. The revisional authority must identify an actual error from the assessment record and demonstrate resulting prejudice; it cannot order a fresh investigation without establishing both statutory conditions. The stated result was quashing of the revisionary order and allowance of the assessee's appeal.
Revision under section 263 requires the assessment order to be both erroneous and prejudicial to the interests of the Revenue. The distinction between lack of inquiry and inadequate inquiry is material: where the Assessing Officer has examined relevant expenses, related-party payments, GST-exempt services, financial records, returns, GST details, TDS particulars and supplier-level material, revision cannot be based merely on a view that further verification was desirable. The revisional authority must identify an actual error from the assessment record and demonstrate resulting prejudice; it cannot order a fresh investigation without establishing both statutory conditions. The stated result was quashing of the revisionary order and allowance of the assessee's appeal.
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