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Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
HC allowed the writ petition, quashing the impugned order dated 28.03.2023 passed u/s 264 and remanding the matter to R-2 for fresh consideration. HC held that mere filing of a revenue appeal against a jurisdictional ITAT decision does not dilute its binding nature; revenue authorities must follow such precedent unless properly distinguished with cogent reasons. HC rejected the contention that revision u/s 264 cannot cover issues not claimed in, or accepted in, the return, holding that automatic, unamendable AMT computation in the ITR utility does not amount to conscious acceptance of tax under s.115JC. HC further held that an intimation u/s 143(1) is amenable to revision u/s 264, directing R-2 to reconsider the assessee's claim in light of the jurisdictional ITAT ruling.
HC allowed the writ petition, quashing the impugned order dated 28.03.2023 passed u/s 264 and remanding the matter to R-2 for fresh consideration. HC held that mere filing of a revenue appeal against a jurisdictional ITAT decision does not dilute its binding nature; revenue authorities must follow such precedent unless properly distinguished with cogent reasons. HC rejected the contention that revision u/s 264 cannot cover issues not claimed in, or accepted in, the return, holding that automatic, unamendable AMT computation in the ITR utility does not amount to conscious acceptance of tax under s.115JC. HC further held that an intimation u/s 143(1) is amenable to revision u/s 264, directing R-2 to reconsider the assessee's claim in light of the jurisdictional ITAT ruling.
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