https://www.taxtmi.com/caselaws?id=783250 ITAT Pune quashed the revisionary order u/s 263 passed by the CIT against the assessee, an ITES and software development service provider. The Tribunal held that all receipts were from associated enterprises and that, as per the accepted transfer pricing methodology, the assessee recovered its costs, including the entire repairs and maintenance expenditure, with a 14.5% mark-up. Since the impugned repairs and maintenance items, including computer peripherals, formed part of operating expenditure fully charged to AEs, the assessment order could not be characterized as erroneous or prejudicial to the interests of the Revenue. Consequently, the twin conditions for valid invocation of s.263 were not satisfied, and the assessee's appeal was allowed. en-us Fri, 28 Nov 2025 00:00:00 +0530 Fri, 12 Dec 2025 08:55:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783250 ITAT Pune quashed the revisionary order u/s 263 passed by the CIT against the assessee, an ITES and software development service provider. The Tribunal held that all receipts were from associated enterprises and that, as per the accepted transfer pricing methodology, the assessee recovered its costs, including the entire repairs and maintenance expenditure, with a 14.5% mark-up. Since the impugned repairs and maintenance items, including computer peripherals, formed part of operating expenditure fully charged to AEs, the assessment order could not be characterized as erroneous or prejudicial to the interests of the Revenue. Consequently, the twin conditions for valid invocation of s.263 were not satisfied, and the assessee's appeal was allowed. Case-Laws Income Tax Fri, 28 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783250