CIT's revision u/s 263 challenged; no TPO reference needed as per clause 3.3 instructions in ALP case.

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....Revision u/s 263 by CIT - Faulty computation of ALP - As per CIT assessment is erroneous as reference to TPO was not made - The said clause 3.3 of the Instruction specifies three situations and we find that none of the situation is applicable in the case of the assessee. - it cannot be said that the assessment is erroneous as reference to TPO was not made. - AT....