Initiation of revisionary proceedings based on proposal by AO for making revision lacks jurisdiction

Volkswagen India Private Limited Vs PCIT (ITAT Pune)

ITAT Pune held that initiation of revisionary proceedings under section 263, based only on the proposal sent by AO for making revision, lacked jurisdiction and hence revisionary proceedings liable to be set aside.

Facts- The assessee filed its return declaring Nil income. The assessment was completed by making addition on account of certain transfer pricing adjustment. PCIT issued a show cause notice observing that the assessment proceedings for the

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