Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Revision u/s 263 - The Pr. CIT has not pointed out as to what is the error committed by the AO in accepting the replies from various parties. Without pointing out any defects, it cannot be said that there is an error which caused prejudice to the interest of the Revenue. This is not a case of lack of enquiry or non-application of mind. The AO has made an enquiry and has taken a plausible view on the issues. - AT
Revision u/s 263 - The Pr. CIT has not pointed out as to what is the error committed by the AO in accepting the replies from various parties. Without pointing out any defects, it cannot be said that there is an error which caused prejudice to the interest of the Revenue. This is not a case of lack of enquiry or non-application of mind. The AO has made an enquiry and has taken a plausible view on the issues. - AT
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