Held that The Principal Commissioner in accordance with the provisions of the Act had given an opportunity of being heard to the assessee, determined the amount of the adjustment made by the Transfer Pricing Officer that was not brought to tax and set aside the order of the Assessing Officer directing him to rectify the order to the extent of the adjustment made by the Transfer Pricing Officer. Revision order is held to be valid. (AY.2012-13)
Actia (India) Pvt. Ltd. v. PCIT (2022) 93 ITR 65 (SN) (Delhi)(Trib.)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Transfer pricing adjustment-Failure by Assessing Officer to make assessment in conformity with order of Transfer Pricing Officer-Revision is valid. [S. 92CA]