PCIT Must Revise Erroneous Assessment Orders u/s 263; No Limits on Transfer Pricing Adjustments Review.

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....Revision u/s 263 - TP Adjustment - once it is proved that assessment order is erroneous and prejudicial to the interest of revenue, the PCIT has no option except to exercise his jurisdiction under section 263. There is no bar in section 263 that the ld PCIT cannot revise the issue where it contained the determination of Arm’s Length Price. - AT....