SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
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Revision u/s 263 - Lack of enquiry or no enquiry - the assessment order passed by the AO is erroneous in so far as it is prejudicial to the interest of the revenue - the AO after collection of certain evidences should embark upon further investigation so as to ascertain the true colours of the transactions, because, what is apparent is not real. However, the AO simply called for certain details on the issue of buyback of shares, but did not reach to a logical conclusion on the issue, even though, there is a scope for application of provisions of Sec.2(22)(a) / 2(22)(d) of the Act. Therefore, we are of the considered view that there is no error in reasons given by the ld. CIT to exercise his jurisdiction. - AT
Revision u/s 263 - Lack of enquiry or no enquiry - the assessment order passed by the AO is erroneous in so far as it is prejudicial to the interest of the revenue - the AO after collection of certain evidences should embark upon further investigation so as to ascertain the true colours of the transactions, because, what is apparent is not real. However, the AO simply called for certain details on the issue of buyback of shares, but did not reach to a logical conclusion on the issue, even though, there is a scope for application of provisions of Sec.2(22)(a) / 2(22)(d) of the Act. Therefore, we are of the considered view that there is no error in reasons given by the ld. CIT to exercise his jurisdiction. - AT
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