https://www.taxtmi.com/caselaws?id=438686 Explanation 2(c) to section 263 applies where an assessment order is not made in accordance with a Board instruction under section 119. CBDT Instruction No. 3/2016 required a reference to the Transfer Pricing Officer in cases selected on transfer pricing risk parameters, subject to prescribed approval. Because the assessing officer did not make the mandatory reference and the assessment order did not record any non-examination of the transfer pricing issue under the Instruction, the order was treated as erroneous and prejudicial to the interests of revenue. The revision order was upheld, and further objections were left to be raised in the set-aside proceedings. en-us Fri, 12 May 2023 00:00:00 +0530 Wed, 07 Jun 2023 08:50:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=438686 Explanation 2(c) to section 263 applies where an assessment order is not made in accordance with a Board instruction under section 119. CBDT Instruction No. 3/2016 required a reference to the Transfer Pricing Officer in cases selected on transfer pricing risk parameters, subject to prescribed approval. Because the assessing officer did not make the mandatory reference and the assessment order did not record any non-examination of the transfer pricing issue under the Instruction, the order was treated as erroneous and prejudicial to the interests of revenue. The revision order was upheld, and further objections were left to be raised in the set-aside proceedings. Case-Laws Income Tax Fri, 12 May 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=438686