https://www.taxtmi.com/caselaws?id=763046 The ITAT Delhi set aside the CIT's revision order under section 263, ruling that the CIT erroneously assumed jurisdiction. The tribunal found that the TPO had conducted specific enquiries regarding international transactions and received specific replies from the assessee, contrary to the CIT's assertion that no proper enquiry was made. Following the precedent in Clix Finance India Pvt Ltd, the tribunal held that inadequacy of enquiry alone cannot justify invoking section 263 powers. The TPO's original order accepting arm's length pricing was restored, deciding in favor of the assessee. en-us Thu, 28 Mar 2024 00:00:00 +0530 Wed, 11 Dec 2024 12:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763046 The ITAT Delhi set aside the CIT's revision order under section 263, ruling that the CIT erroneously assumed jurisdiction. The tribunal found that the TPO had conducted specific enquiries regarding international transactions and received specific replies from the assessee, contrary to the CIT's assertion that no proper enquiry was made. Following the precedent in Clix Finance India Pvt Ltd, the tribunal held that inadequacy of enquiry alone cannot justify invoking section 263 powers. The TPO's original order accepting arm's length pricing was restored, deciding in favor of the assessee. Case-Laws Income Tax Thu, 28 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763046