Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
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Revision u/s 263 by CIT - it appropriate to quote that the legislative amendment made in section 263 by way of insertion of Explanation 2 in Finance Act, 2015 w.e.f. 01.06.2015 that an assessment order passed without making enquiry or verification is deemed to be an erroneous one in so far as it is prejudicial to the interest of Revenue. We thus uphold the learned PCIT's revision jurisdiction direction herein in principle. It shall however be open to the assessee to raise all factual as well as legal arguments before the Assessing Officer in support of her impugned exemption claim as per law; if so advised in consequential proceedings. - AT
Revision u/s 263 by CIT - it appropriate to quote that the legislative amendment made in section 263 by way of insertion of Explanation 2 in Finance Act, 2015 w.e.f. 01.06.2015 that an assessment order passed without making enquiry or verification is deemed to be an erroneous one in so far as it is prejudicial to the interest of Revenue. We thus uphold the learned PCIT's revision jurisdiction direction herein in principle. It shall however be open to the assessee to raise all factual as well as legal arguments before the Assessing Officer in support of her impugned exemption claim as per law; if so advised in consequential proceedings. - AT
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