No section 263 Proceedings for related party transaction excluded from definition of specified domestic transaction

Ashish Subodchandra Shah Vs PCIT (ITAT Ahmedabad) Facts- Assessee declared the total income under ROI as INR 33,98,080. However, AO passed the assessment order and determined the taxable income as INR 57,75,980. The Commissioner found that one of the specific domestic transaction was undervalued and hence he referred the same to TPO and issued a notice under section 263. Conclusion- On the facts of the present case, when the Commissioner issued a show cause notice under section 263 and ultimately passed impugned order; by that time the alleged domestic transaction of purchase from related part...