Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Revision u/s 263 - It is evident that A.O. made enquiries on the issue and assessee complied to the enquiries and filed all the required details. Thus, it is not a case where that A.O. made no enquiry or verification which should have been made. It is clear from reading of notice u/s 263 of the Act, that the proceedings u/s 263 has been started on the same issue which have already been considered and examined by the then A.O. - Revision order set aside - AT
Revision u/s 263 - It is evident that A.O. made enquiries on the issue and assessee complied to the enquiries and filed all the required details. Thus, it is not a case where that A.O. made no enquiry or verification which should have been made. It is clear from reading of notice u/s 263 of the Act, that the proceedings u/s 263 has been started on the same issue which have already been considered and examined by the then A.O. - Revision order set aside - AT
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