https://www.taxtmi.com/caselaws?id=790693 Revision under section 263 can extend to a Transfer Pricing Officer's order where the order is passed after the amendment recognising such revisability. On the standby letter of credit arrangements, the absence of enquiry into the agreements, risk allocation, commission basis, recovery from the associated enterprise, and arm's length benchmarking made the order erroneous and prejudicial to the Revenue. The fact that the expenditure may otherwise be considered under section 37(1) did not override the Chapter X transfer pricing inquiry. The revision was therefore sustained and a fresh examination of the international transaction was justified. en-us Tue, 24 Feb 2026 00:00:00 +0530 Wed, 29 Apr 2026 08:16:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790693 Revision under section 263 can extend to a Transfer Pricing Officer's order where the order is passed after the amendment recognising such revisability. On the standby letter of credit arrangements, the absence of enquiry into the agreements, risk allocation, commission basis, recovery from the associated enterprise, and arm's length benchmarking made the order erroneous and prejudicial to the Revenue. The fact that the expenditure may otherwise be considered under section 37(1) did not override the Chapter X transfer pricing inquiry. The revision was therefore sustained and a fresh examination of the international transaction was justified. Case-Laws Income Tax Tue, 24 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790693