https://www.taxtmi.com/caselaws?id=446771 The ITAT Mumbai upheld the CIT's revision order under section 263 against the TPO's order dated 27/1/2021. The TPO had passed an order under section 92CA(3) without examining the arm's length price of international transactions involving export sales and imports, despite the assessee not submitting Form 3CEB. The ITAT rejected the assessee's argument that revision under section 263 for TP adjustments could only be made from 1/4/2022 onwards, holding that the date of examination of records is relevant, not the date of the original order. The TPO's order was deemed erroneous and prejudicial to revenue due to complete absence of inquiry regarding transfer pricing benchmarking. en-us Wed, 29 Nov 2023 00:00:00 +0530 Sat, 09 Dec 2023 10:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446771 The ITAT Mumbai upheld the CIT's revision order under section 263 against the TPO's order dated 27/1/2021. The TPO had passed an order under section 92CA(3) without examining the arm's length price of international transactions involving export sales and imports, despite the assessee not submitting Form 3CEB. The ITAT rejected the assessee's argument that revision under section 263 for TP adjustments could only be made from 1/4/2022 onwards, holding that the date of examination of records is relevant, not the date of the original order. The TPO's order was deemed erroneous and prejudicial to revenue due to complete absence of inquiry regarding transfer pricing benchmarking. Case-Laws Income Tax Wed, 29 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446771