Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Page of 4823
Press 'Enter' after typing page number.
6881 to 6900 of 96456 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
ITAT held that a revision under section 263 could not be exercised where the assessment order had been passed in conformity with directions of the DRP, a superior collegial authority. Once the AO gives effect to binding DRP directions and frames the final order accordingly, the Commissioner lacks revisional jurisdiction over that order. On that basis, the section 263 order was quashed for want of jurisdiction, and the remaining grounds were treated as infructuous.
ITAT held that a revision under section 263 could not be exercised where the assessment order had been passed in conformity with directions of the DRP, a superior collegial authority. Once the AO gives effect to binding DRP directions and frames the final order accordingly, the Commissioner lacks revisional jurisdiction over that order. On that basis, the section 263 order was quashed for want of jurisdiction, and the remaining grounds were treated as infructuous.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4823 
Join Channel 
