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    <title>2019 (12) TMI 205 - ITAT INDORE</title>
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    <description>Revision under section 263 could not be sustained where it rested solely on the Assessing Officer&#039;s failure to refer specified domestic transactions for transfer pricing examination. The omission of section 92BA(i) was held material because the provision had already been omitted when the revisionary order was passed, and an omitted provision is treated as if it had never existed. The view that the pre-omission assessment year preserved the revisionary basis was rejected. The revisionary order was quashed and the appeal was allowed in favour of the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=389322</link>
      <description>Revision under section 263 could not be sustained where it rested solely on the Assessing Officer&#039;s failure to refer specified domestic transactions for transfer pricing examination. The omission of section 92BA(i) was held material because the provision had already been omitted when the revisionary order was passed, and an omitted provision is treated as if it had never existed. The view that the pre-omission assessment year preserved the revisionary basis was rejected. The revisionary order was quashed and the appeal was allowed in favour of the assessee.</description>
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      <pubDate>Thu, 21 Nov 2019 00:00:00 +0530</pubDate>
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