Section 263 Revision: CIT Can Address Unconsidered Issues in Transfer Pricing Orders Included in Assessment Orders.

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....Revision u/s 263 - TP Adjustment - Where the direction of the DRP have been held to be part of the assessment order, then, there can be no doubt that TP order is also part of assessment order and is thus amenable to jurisdiction of the CIT u/s.263 of the Act and particularly on the issues which were not considered by the TPO and DRP. - AT....