CIT's Section 263 Revision Order on DAPE's FAR Analysis Overturned Due to Lack of Arm's Length Price Assessment.

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....Revision u/s 263 by CIT - There is no such finding about the payment to the dependent agent being less than the arm’s length price of services rendered by the dependent agent, in the present case, even though there is a finding about questioning the DAPE’s FAR analysis. The Commissioner ought to have examined the arm’s length price determination in respect of the services rendered by the dependent agent, in this context. That exercise has also not been done. - Revision order set aside - AT....