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 - The revenue is disputing on non conduct of enquiry, but we find the assessee firm has discharged its burden of proof on submitting the vital requisite details called for by the assessing officer by issue of statutory notice U/sec 142(1) of the Act along with the questioner which cannot be over looked. Since the information was available with the A.O in the course of the assessment, the A.O. has considered the facts, submissions and evidences filed and took a view. - AT
Revision u/s 263 - The revenue is disputing on non conduct of enquiry, but we find the assessee firm has discharged its burden of proof on submitting the vital requisite details called for by the assessing officer by issue of statutory notice U/sec 142(1) of the Act along with the questioner which cannot be over looked. Since the information was available with the A.O in the course of the assessment, the A.O. has considered the facts, submissions and evidences filed and took a view. - AT
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