Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Revision u/s 263 by CIT - A reading of the same clearly shows that after having made a contradictory observation on issue of lack of enquiry of cash deposit aspect for which the assessment was taken up, the ld. PCIT went on virtually issue a notice u/s 143(2) and embark upon fishing and roving expedition. PCIT never mentioned in his order before issuing this second notice as to how the Assessment Order in this regard was erroneous so as to be prejudicial to the interest of the revenue. Hence, this part of the ld. PCIT’s order wherein notice was issued dehors any finding or even mention of the AO’s order being erroneous or prejudicial to the interest of the revenue is not at all sustainable. - AT
Revision u/s 263 by CIT - A reading of the same clearly shows that after having made a contradictory observation on issue of lack of enquiry of cash deposit aspect for which the assessment was taken up, the ld. PCIT went on virtually issue a notice u/s 143(2) and embark upon fishing and roving expedition. PCIT never mentioned in his order before issuing this second notice as to how the Assessment Order in this regard was erroneous so as to be prejudicial to the interest of the revenue. Hence, this part of the ld. PCIT’s order wherein notice was issued dehors any finding or even mention of the AO’s order being erroneous or prejudicial to the interest of the revenue is not at all sustainable. - AT
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