Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Revision u/s 263 - order framed u/s 153A - The Tribunal (ITAT) held that, the assessment orders approved u/s 153D cannot be revised u/s 263 without first revising the approval itself. The AO conducted adequate and reasonable enquiries, fulfilling the requirements of a proper assessment. - The Tribunal emphasized the legal principle that when two views are possible, the AO's decision to adopt one permissible view cannot be deemed erroneous or prejudicial to the interests of the revenue.
Revision u/s 263 - order framed u/s 153A - The Tribunal (ITAT) held that, the assessment orders approved u/s 153D cannot be revised u/s 263 without first revising the approval itself. The AO conducted adequate and reasonable enquiries, fulfilling the requirements of a proper assessment. - The Tribunal emphasized the legal principle that when two views are possible, the AO's decision to adopt one permissible view cannot be deemed erroneous or prejudicial to the interests of the revenue.
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