https://www.taxtmi.com/caselaws?id=759708 The ITAT Delhi quashed the PCIT's revision order u/s 263. The PCIT had invoked revision jurisdiction claiming the AO erred by not waiting for the TPO's order u/s 92CA(3) regarding transfer pricing adjustments for international transactions. The ITAT held that when original assessment proceedings get abated due to search proceedings u/s 153C, and the AO chose not to make fresh reference to TPO u/s 92CA(1), no error could be attributed to the AO's order. Additionally, the PCIT failed to establish that the prior approval granted u/s 153D was erroneous, which was necessary before assuming revision jurisdiction. The revision order was quashed on multiple grounds. en-us Wed, 25 Sep 2024 00:00:00 +0530 Sat, 05 Oct 2024 10:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759708 The ITAT Delhi quashed the PCIT's revision order u/s 263. The PCIT had invoked revision jurisdiction claiming the AO erred by not waiting for the TPO's order u/s 92CA(3) regarding transfer pricing adjustments for international transactions. The ITAT held that when original assessment proceedings get abated due to search proceedings u/s 153C, and the AO chose not to make fresh reference to TPO u/s 92CA(1), no error could be attributed to the AO's order. Additionally, the PCIT failed to establish that the prior approval granted u/s 153D was erroneous, which was necessary before assuming revision jurisdiction. The revision order was quashed on multiple grounds. Case-Laws Income Tax Wed, 25 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759708