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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Validity of Revision u/s 263 - Even if it were to be accepted that the assessment has been completed by mere reference to the provisions of section 44AD by the AO, even then, in our view Principal CIT was correct in observing that reference could not have been drawn to the said provisions as the total quantum of transaction was exceeding Rs. 60 lacs in the year under consideration. - Revision order sustained - AT
Validity of Revision u/s 263 - Even if it were to be accepted that the assessment has been completed by mere reference to the provisions of section 44AD by the AO, even then, in our view Principal CIT was correct in observing that reference could not have been drawn to the said provisions as the total quantum of transaction was exceeding Rs. 60 lacs in the year under consideration. - Revision order sustained - AT
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