Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Revisional jurisdiction under section 263 was examined: the twin conditions of the order being erroneous and prejudicial to revenue were not met because the Assessing Officer issued detailed queries, obtained submissions and documents, and applied his mind before accepting returned income. Explanation 2(a) did not apply as inquiries were made. Clause (d) of Explanation 2 could not be invoked since the AO adopted a plausible view supported by High Court precedents and the Supreme Court decision relied on was distinguishable on its facts. The Tribunal set aside the Principal Commissioner's revision order and allowed the assessee's appeal.
Revisional jurisdiction under section 263 was examined: the twin conditions of the order being erroneous and prejudicial to revenue were not met because the Assessing Officer issued detailed queries, obtained submissions and documents, and applied his mind before accepting returned income. Explanation 2(a) did not apply as inquiries were made. Clause (d) of Explanation 2 could not be invoked since the AO adopted a plausible view supported by High Court precedents and the Supreme Court decision relied on was distinguishable on its facts. The Tribunal set aside the Principal Commissioner's revision order and allowed the assessee's appeal.
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