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Revision u/s 263 - it was incumbent upon the A.O. to refer the transfer pricing matter to the TPO. The A.O. having failed to do so, the case admittedly falls under the jurisdiction of the Pr. CIT as an order by the A.O. which is erroneous so as to be prejudicial to the interest of the Revenue.
Revision u/s 263 - it was incumbent upon the A.O. to refer the transfer pricing matter to the TPO. The A.O. having failed to do so, the case admittedly falls under the jurisdiction of the Pr. CIT as an order by the A.O. which is erroneous so as to be prejudicial to the interest of the Revenue.
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TaxTMI 
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