2023 (3) TMI 1543

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....EE RAJKUMAR & MANASA ANANTAN, ADVOCATES FOR THE RESPONDENT: SRI. Y.V. RAVIRAJ, ADVOCATE ORDER 1. Petitioner is a Private Limited Company and is assessed for income tax. In respect of the assessment year 2002-03, the jurisdictional Transfer Pricing Officer passed an order dated 31.03.2017, determining the Arms Length Price. The said order is perceived as beneficial to the assessee and adverse to....

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....prejudicial to the revenue. Section 263 (2) reads as under: "263. (1) XXXXXX (2) No order shall be made under sub- section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed." Thus, any order under Section 263 of the Act can be passed only within two years from the date of the order sought to be revised. 4. In the instant c....