https://www.taxtmi.com/caselaws?id=314214 ITAT Pune held that CIT was not justified in exercising revisionary powers under Section 263 regarding transfer pricing adjustments. The assessee's treatment of exit costs of TBA-10 machines as extraordinary items excluded from operating profit was accepted by TPO without adjustment. AO followed TPO's binding order under Section 92CA(4), making no error in the assessment. CIT failed to establish both conditions required under Section 263 - that the order was erroneous and prejudicial to revenue interests. The exclusion of extraordinary exit costs from operating margin computation was upheld following precedent. Assessee's appeal was partly allowed. en-us Fri, 18 Nov 2016 00:00:00 +0530 Sun, 26 May 2024 00:02:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=314214 ITAT Pune held that CIT was not justified in exercising revisionary powers under Section 263 regarding transfer pricing adjustments. The assessee's treatment of exit costs of TBA-10 machines as extraordinary items excluded from operating profit was accepted by TPO without adjustment. AO followed TPO's binding order under Section 92CA(4), making no error in the assessment. CIT failed to establish both conditions required under Section 263 - that the order was erroneous and prejudicial to revenue interests. The exclusion of extraordinary exit costs from operating margin computation was upheld following precedent. Assessee's appeal was partly allowed. Case-Laws Income Tax Fri, 18 Nov 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=314214