https://www.taxtmi.com/caselaws?id=768673 ITAT Delhi quashed PCIT's revision order under Section 263, holding the assumption of jurisdiction was flawed and mechanical. The Tribunal found PCIT's directions were vague without identifying specific errors in AO's assessment. Key issues included: domestic transfer pricing adjustments were impermissible post-omission of Section 92BA(i); share premium to joint venture partners was adequately examined; revenue recognition under POCM wouldn't prejudice revenue due to timing differences; borrowing costs from CCDs/OCDs were already scrutinized by TPO; and land purchase rights pertained to different assessment year. PCIT's fishing and roving enquiry approach was legally impermissible for Section 263 jurisdiction. en-us Wed, 12 Mar 2025 00:00:00 +0530 Fri, 11 Apr 2025 08:40:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768673 ITAT Delhi quashed PCIT's revision order under Section 263, holding the assumption of jurisdiction was flawed and mechanical. The Tribunal found PCIT's directions were vague without identifying specific errors in AO's assessment. Key issues included: domestic transfer pricing adjustments were impermissible post-omission of Section 92BA(i); share premium to joint venture partners was adequately examined; revenue recognition under POCM wouldn't prejudice revenue due to timing differences; borrowing costs from CCDs/OCDs were already scrutinized by TPO; and land purchase rights pertained to different assessment year. PCIT's fishing and roving enquiry approach was legally impermissible for Section 263 jurisdiction. Case-Laws Income Tax Wed, 12 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768673