Section 263 order based on omitted provision at the time of order not valid

Swastik Coal Corporation Pvt. Ltd. Vs Pr. CIT (ITAT Indore)

The basis of exercising of revisionary jurisdiction u/s 263 of the Act as per Ld. Pr. CIT is that transfer pricing related issues were not examined by the A.O. since the transaction carried out by the assessee are covered under specific domestic transactions. The contention of the assessee is that Ld. Pr. CIT ought not to have invoked the provisions of section 263 of the Act as in the present case, major transactions were carried out with M/s. ARKA

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