Revision u/s 263 - TP Adjustment - Where the direction of the ...

Case Laws Income Tax

March 9, 2021

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

View Source

← Previous Next →

Revision u/s 263 - TP Adjustment - Where the direction of the ...

Case Laws Income Tax

March 9, 2021

You may also like:

Transfer pricing officer (TPO) erred by considering non-associated enterprise (non-AE) revenue and costs while computing transfer pricing (TP) adjustment, contrary to...

Revision u/s 263 - addition u/s 68 - The Assessing Officer has taken a possible view. When the Assessing Officer follows the direction of the Ld. Pr. CIT, in his order...

Revision u/s 263 - Directions of the Ld.CIT given to the AO to verify the unsecured creditors, unsecured loans, the AO in his fresh assessment order passed u/s 143(3)...

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...

TP adjustment - AO/TPO has not followed direction of DRP - As per section 144C(13) the AO is bound to pass the final assessment order in conformity with the direction of...

The Appellate Tribunal (ITAT) considered a case involving Transfer Pricing (TP) adjustments for both US and non-US transactions. The Tax Authorities computed TP...

Revision u/s 263 - the ld PCIT had invoked revision jurisdiction u/s 263 of the Act on the very same point of allowability of LTCL. Hence it could be safely concluded...

Scope of appeal before CIT(A) after revision order u/s 263 - Since, pending proceedings before the Ld.CIT(A) is with reference to additions made in pursuant to...

Revision u/s 263 by CIT - Non reference of matter to the TPO - no prudent business person properly instructed in law would have inferred the TP risk parameter as a...

TP Adjustment - TPO rejected the TP study undertaken by the assessee and proceeded to apply TNMM at the entity level which the assessee company has objected to - CIT(A)...

Validity of revision u/s 263 - subsequent revision orders - first order set aside by PCIT - ITAT quashing revisionary proceedings - adoption of accrual basis of...

Revision u/s 263 by CIT - the assessee had duly explained as to why certain receipts though subjected to TDS, would not be liable to be offered to tax such as...

TP adjustment - Direction in remand proceeding - Customs Duty Adjustment, Air Freight Adjustment and Foreign Exchange Adjustment - If the Tribunal has fixed how such...

Revision u/s 263 - Lack of enquiry is a reason for taking up the case for revision u/s 263 of the Act but the inadequate enquiry cannot be a reason for taking up the...

Appraisal report available but AO ignored, a fit case for revision u/s 263 - HC

Quick Updates: