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 - The Appellate Tribunal found that the PCIT's assumption of jurisdiction under Section 263 was not justified. It observed that the assessment order was not erroneous, as the Assessing Officer had accepted the returned income and made no additions based on the reasons recorded for reopening the assessment. Therefore, the Tribunal set aside the PCIT's order and restored that of the Assessing Officer.
Revision u/s 263 by CIT - The Appellate Tribunal found that the PCIT's assumption of jurisdiction under Section 263 was not justified. It observed that the assessment order was not erroneous, as the Assessing Officer had accepted the returned income and made no additions based on the reasons recorded for reopening the assessment. Therefore, the Tribunal set aside the PCIT's order and restored that of the Assessing Officer.
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