https://www.taxtmi.com/caselaws?id=463717 ITAT, Jaipur allowed the appeal, holding that the AO's assessment-though reflecting TP adjustments under s. 92CA(3)-was not erroneous or prejudicial merely because penalty proceedings under s. 270A were not initiated. The tribunal found the s. 92CA(3) remark only required the AO to examine the need for penalty, not to mandatorily impose it, and that the AO had considered the DCIT (TP) order and applied his mind. Revision under s. 263 could not be sustained on that basis. en-us Thu, 26 Dec 2024 00:00:00 +0530 Fri, 12 Sep 2025 19:00:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463717 ITAT, Jaipur allowed the appeal, holding that the AO's assessment-though reflecting TP adjustments under s. 92CA(3)-was not erroneous or prejudicial merely because penalty proceedings under s. 270A were not initiated. The tribunal found the s. 92CA(3) remark only required the AO to examine the need for penalty, not to mandatorily impose it, and that the AO had considered the DCIT (TP) order and applied his mind. Revision under s. 263 could not be sustained on that basis. Case-Laws Income Tax Thu, 26 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463717