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Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Revision u/s 263 - The ITAT held that the AO had conducted adequate inquiries into the sales promotion expenses, as evidenced by the issuance of specific queries to the assessee. The AO's decision to accept the assessee's claims was based on the responses and documents provided. The ITAT found that the PCIT's revision under Section 263, alleging non-verification of the said expenses, was not justified as the AO had made necessary inquiries and applied his mind to the information available.
Revision u/s 263 - The ITAT held that the AO had conducted adequate inquiries into the sales promotion expenses, as evidenced by the issuance of specific queries to the assessee. The AO's decision to accept the assessee's claims was based on the responses and documents provided. The ITAT found that the PCIT's revision under Section 263, alleging non-verification of the said expenses, was not justified as the AO had made necessary inquiries and applied his mind to the information available.
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