Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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.
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