Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
The AO's order was not erroneous or prejudicial to the revenue's interests. The filing fee for increasing share capital was rightly allowed as revenue expenditure, supported by audited financials and judicial precedent. The AO examined the revised computation, disallowed deduction u/s 35ABB after due application of mind, and passed the assessment order at the originally returned income. The PCIT's revision u/s 263, deeming the AO's order erroneous and prejudicial, is unjustified and quashed. The assessee's appeal is allowed.
The AO's order was not erroneous or prejudicial to the revenue's interests. The filing fee for increasing share capital was rightly allowed as revenue expenditure, supported by audited financials and judicial precedent. The AO examined the revised computation, disallowed deduction u/s 35ABB after due application of mind, and passed the assessment order at the originally returned income. The PCIT's revision u/s 263, deeming the AO's order erroneous and prejudicial, is unjustified and quashed. The assessee's appeal is allowed.
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