Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Revision u/s 263 - Ld. CIT without pointing out any infirmity in the reply /explanation of the assessee could not concluded that the assessment order passed by the AO was found to be ‘erroneous and prejudicial to the interest of revenue’ - explanation-2(a) to section 263 does not authorize or give unfettered powers to the Commissioner to revise each and every order
Revision u/s 263 - Ld. CIT without pointing out any infirmity in the reply /explanation of the assessee could not concluded that the assessment order passed by the AO was found to be ‘erroneous and prejudicial to the interest of revenue’ - explanation-2(a) to section 263 does not authorize or give unfettered powers to the Commissioner to revise each and every order
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