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of The ITAT Rajkot dealt with a case involving revision u/s 263 of the Income Tax Act regarding orders u/s 92CA. The amendment to section 263 clarified the jurisdiction to revise such orders, addressing a lacuna highlighted in a previous case. The amendment was deemed clarificatory and retrospective. The CIT's jurisdiction to revise TPO orders u/s 92CA was upheld. The case involved international transactions on Compulsorily Convertible Debentures (CCDs) deemed as hybrid instruments, not pure debt. The CIT's findings on the nature of CCDs were upheld, rejecting the assessee's arguments. The addendum introduced during revisionary proceedings was not considered. The CIT's decision on the ALP of interest paid on CCDs was supported, as the TPO's acceptance of the transaction as arm's length was deemed erroneous. The TPO's failure to conduct necessary inquiries caused prejudice to the revenue. The CIT's decision against the assessee was confirmed.
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