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2016 (6) TMI 208 - ITAT PUNE

2016 (6) TMI 208 - ITAT PUNE - TMI - Transfer pricing adjustment - existence of associate enterprises - connection between the two concerns by way of management, control or capital in either of two enterprises - Held that:- The assessee had entered into a purchase agreement with Cummins for the supply of Shroud Plates in August, 2005. The perusal of terms of the agreement reflects the understanding between the assessee with its purchaser Cummins for the supply of goods within time frame and the .....

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it was agreed upon that the supplier i.e. assessee had to offer goods at competitive market rates and in case an alternate supplier was found, who offers more competitive cost, then the assessee would get 30 days time to respond to the competitive threat and in case, the assessee is unable to meet the competitive threat and then, mutually acceptable phase out would be negotiated between the parties. The aforesaid clause agreed upon between the parties is used by the authorities below to imply th .....

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is controlled by purchaser. In any case, the total exports of the assessee to Cummins constitute 18.76% of the total turnover and the extent of exports cannot be held to influence the price of assessee’s goods. The TPO while starting the TP proceedings had observed that the assessee has shown total earning in foreign currency at ₹ 9.40 crores, against which the export sales made to Cummins were to the tune of ₹ 9.33 crores. However, in view of the entirety of the facts, where the exp .....

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nce both the enterprises have not fulfilled the conditions laid down in section 92A(1) of the Act and where there is no connection whatsoever by way of participation in management or control or capital by the entities or its subsidiaries, either directly or indirectly the assessee and Cummins cannot be said to be associate enterprises in order to apply the provisions of Chapter X of the Act.

In the absence of assessee having entered into any international transactions with any associ .....

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parting, we would like to clarify herein that admittedly, in case the two concerns satisfy the conditions of section 92A(1) of the Act to be deemed associate enterprises of each other, then on fulfillment of such preliminary conditions, the Assessing Officer has the power on prima facie satisfaction that the international transaction between two such enterprises is required to be benchmarked, can make a reference to the TPO, but the first condition to be satisfied is whether the connection betwe .....

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the EOU unit does not survive in view of our holding the assessment order passed to be beyond limitation. - Decided in favour of assessee. - ITA No.580/PN/2014, ITA No.974/PN/2014, ITA No.581/PN/2014 - Dated:- 29-4-2016 - MS. SUSHMA CHOWLA, JM AND SHRI PRADIP KUMAR KEDIA, AM For The Assessee : Shri Nikhil S. Pathak For The Revenue : Shri Mazhar Akram ORDER PER SUSHMA CHOWLA, JM: Out of this bunch of appeals, cross appeals filed by the Revenue and assessee are against order of CIT(A)-III, Pune, .....

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onvenience. 3. The Revenue in ITA No. 580/PN/2014 has raised the following grounds of appeal:- 1. The order of the Commissioner of Income-tax (Appeals) is contrary to law and to the facts and circumstances of the case. 2. On the facts and in the circumstance of the case and in law, the learned Commissioner of Income Tax (Appeals)-IIl, Pune has erred in giving relief of ₹ 92,75,656/- by holding that when the assessee exercises the option, only to losses of the year beginning form the initia .....

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order of the Commissioner of Income-tax (Appeals) may be vacated and that of the Assessing Officer be restored. 4. The appellant craves leave to add, amend, alter or delete any of the above grounds of appeal during the course of the appellate proceedings before the ITAT . 4. The assessee in ITA No. 974/PN/2014 has raised the following grounds of appeal:- 1] The learned CIT(A) erred in holding that the asst. order dated 30.12.2011 was valid in law and not barred by limitation. 2] The learned CIT .....

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been passed by 31st December, 2010 and hence, the said asst. order dated 30.12.2011 is barred by limitation. 4] The learned CIT(A) erred in holding that the learned A.O. was justified in thrusting additional depreciation in respect of new plant and machinery of ₹ 23,45,902/- in respect of the EOU unit while computing the deduction u/s 10B. 5] The learned CIT(A) erred in not appreciating that as per the provisions of section 32, the additional depreciation was not mandatory and hence, ther .....

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end or delete any of the above grounds of appeal. 5. The assessee and the Revenue has filed cross appeals for assessment year 2008-09 and the Revenue is also in appeal in assessment year 2009-10. All the three appeals relating to the same assessee were heard together and are being disposed of by this consolidated order for the sake of convenience. 6. First, we shall take up the appeals filed by the Revenue, wherein in both the appeals, identical issue has been raised by the Revenue against the d .....

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nit No.3, which was 100% EOU and further carrying on the manufacturing activity in non-EOU units, had also declared income from electricity generated from its windmill. The assessee purchased two windmills in financial years 2001-02 and 2002-03. During the year under consideration i.e. assessment year 2008-09, the assessee had claimed deduction under section 80IA(5) of the Act at ₹ 92,75,656/-. The Assessing Officer denied the claim of assessee, in view of brought forward losses in the han .....

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section 80IA(5) of the Act on this ground. 8. Before the CIT(A), the claim of assessee was that it had exercised the option of initial assessment year and assessment year 2007-08 was his initial assessment year and the losses arising therefrom had to be carried forward and not the losses of earlier years which have already been adjusted against income from other sources. The CIT(A) in turn, relying on various decisions including the decision of Tribunal in Serum International Ltd. held that the .....

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012 and 1618/PN/2012, relating to assessment year 2008-09, holding as under:- 26. We have heard the rival contentions and perused the record. The assessee was engaged in the business of trading and dealing in pharmaceuticals. Further, the assessee had set up two windmills for generation of power in assessment year 2002-03. The assessee opted for assessment year 2004-05 as the first year for claim of deduction by exercising the option available under section 80IA(2) of the Act. The Assessing Offi .....

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ted by the assessee for claiming deduction under section 80IA of the Act. The CBDT has also directed the Assessing Officers to allow deduction under section 80IA of the Act in accordance with this clarification. It has also directed that pending litigation on allowability of deduction under section 80IA of the Act shall not be pursued to the extent it relates to interpreting initial assessment year as mentioned in sub-section 5 of section 80IA of the Act. The copy of Circular is placed on record .....

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osses of earlier year which had already been set off against the other income of assessee. It was further held by the Tribunal that the revenue could not notionally bring forward any loss of earlier years which had already been set off against any other income of the assessee and set off the same against the current income of the eligible business. Applying the said decision in assessee s own case and in view of the Circular of CBDT (supra), we uphold the order of CIT(A) and dismiss the grounds .....

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us in assessment year 2008-09 and following the same parity of reasoning, we dismiss the grounds of appeal raised by the Revenue in assessment year 2009-10. 12. Now, coming to the appeal filed by the assessee in assessment year 2008-09. 13. The issue which has to be adjudicated vide grounds of appeal No.1 to 3 raised by the assessee i.e. the order passed by the Assessing Officer whether valid in law being barred by limitation. The grounds of appeal No.4, 5 and 7 raised by the assessee are not pa .....

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e assessee on 08.09.2009. The case was assigned by the CIT-III, Pune and in view of the provisions of section 129 of the Act, fresh notices under sections 143(2) and 143(1) of the Act were issued on 26.07.2010, in response to which, the assessee attended from time to time and furnished the details as asked for. The Assessing Officer noted that the assessee had claimed deduction under section 10B of the Act at ₹ 3,17,85,946/-. The assessee had three units, out of which two units were non-EO .....

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e Act to the Transfer Pricing Officer (TPO) after obtaining statutory approval of CIT-III, Pune and the order of TPO under section 92CA(3) of the Act was also received, wherein the value of international transaction with regard to arm's length price was not disturbed. The assessee took exception to the reference made to the TPO arguing that it was covered by the provisions of Chapter X of the Act as no associate enterprise was established, hence, it was contended that the assessment for asse .....

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oted that the assessee had not filed any Form 3CEB report with respect to international transaction as it contended that it was not attracted by the provisions of Chapter X of the Act. From the submissions made by the assessee before the TPO and during the course of assessment proceedings, the Assessing Officer noted that major part of sales to Cummins Turbo Technologies, USA was Nozzle Shroud Plates although the assessee contends that it exports other articles also to Cummins Turbo Technologies .....

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SA was regulated by Cummins, in the sense that if any alternative supplier offers the product at a more competitive cost, then the assessee would have 30 days to response to the competitive threat and if it does not meet the new product target or provides redesign suggestions to meet the target, the party, Cummins would have the right to explore new sourcing options. The Assessing Officer was of the view that the assessee falls under the clause (i) and clause (m) of section 92A(2) of the Act and .....

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mmins was at arm's length price since the margins of unit-3 were better than those of unit-1 and unit-2. This contention of the assessee was without prejudice to its contention that there was no associate enterprise and no international transaction to attract transfer pricing provisions. The TPO did not make any variation in the arm's length price vis-à-vis international transaction. The Assessing Officer further relied on the decision of Bangalore Bench of Tribunal in the case of .....

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Officer held that the reference to the TPO was valid and assessment order for assessment year 2008-09 was not barred by limitation. The Assessing Officer thereafter, worked out the disallowance under section 80IA(5) of the Act, against which the Revenue is in appeal. We have already adjudicated the said issue. 15. The grievance of the assessee before the CIT(A) was that the order passed by the Assessing Officer on 30.12.2011 was barr ed by limitation. The CIT(A) forwarded the objections of asses .....

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ade to the said concern were ₹ 9.33 crores. As per the Assessing Officer, Cummins was an associate enterprise and the same was covered under the provisions of clause (i) and (m) to section 92A(2) of the Act and since total transactions with the associate enterprise exceeded the limits prescribed by CBDT vide Instruction No.3/2003, approval under section 92CA(1) of the Act was sought. The CIT-III, Pune conveyed the approval vide letter dated 13.12.2012. The CIT(A) while disposing of the app .....

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the TPO and where the Assessing Officer had reached such a prima facie view, on examination of purchase agreement with the associate enterprise in the present case, then the necessary circumstances existed for making such a reference. The second objection of the assessee was with regard to considering Cummins as deemed AE under clause (i) to section 92A(2) of the Act. The CIT(A) in view of section 92A(2)(i) of the Act was of the view that the Legislature had considered any situation where the AE .....

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of the Act were mutually exclusively for each other. The CIT(A) noted the contents of agreement and was of the view that under clause 4.7, there was a requirement on the assessee for reducing cost within 30 days of any competitive pricing offer received by Cummins. Therefore, where Cummins had an upper hand so far as the pricing was concerned, then the provisions of clause (i) to section 92A(1) of the Act were attracted. Further, reference was made to the other clauses i.e. clause 9.1, 11.3, 12. .....

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r the provisions of the Act. The objection of the assessee that Cummins could not be deemed AE under clause (m) of section 92A(2) of the Act, was accepted by the CIT(A), however, it was held that the reference was made by the Assessing Officer to the TPO was fully justified and therefore, assessment completed on 30.12.2011 was not barred by limitation. 16. The assessee is in appeal against the finding of CIT(A) and has raised grounds of appeal No.1 to 3 in this regard. 17. The learned Authorized .....

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. The learned Authorized Representative for the assessee further contended that if there is no AE, there is no question of any reference to the TPO and assessment had to be completed by 31.12.2010 and not by 30.12.2011. He stressed that the reference made by the Assessing Officer to TPO was incorrect. Our attention was drawn to the correspondence with the TPO in this regard, wherein he had stressed that Cummins was not the AE of assessee. He further pointed out that the TPO had not made any adju .....

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er directly or indirectly does not control the assessee, then it does not fall within the definition of clause (a) to Article 9 and also does not fall within clause (b) i.e. any concern controlling both the assessee and Cummins. Since the DTAA was available between India and USA, the provisions of DTAA would prevail in this regard. The learned Authorized Representative for the assessee placed reliance on the ratio laid down by the Hon ble Supreme Court in Union of India & Anr. Vs. Azadi Bach .....

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ight to walk out and also the right to negotiate prices. In this regard, he stressed that the assessment should be considered as time barred. 18. The learned Departmental Representative for the Revenue strongly placed reliance on the order of CIT(A) in this regard. 19. We have heard the rival contentions and perused the record. The definition of associate enterprise is provided in section 92A of the Act, which reads as under:- "92A. Meaning of associated enterprise.- (1) For the purposes of .....

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cipate, directly or indirectly, or through one or more intermediaries, in the management or control or capital of the other enterprise. (2) For the purposes of sub-section (1), two enterprises shall be deemed to be associated enterprises if, at any time during the previous year,- (a) one enterprise holds, directly or indirectly, shares carrying not less than twenty-six per cent of the voting power in the other enterprise; or (b) any person or enterprise holds, directly or indirectly, shares carr .....

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rectors or executive members of the governing board of one enterprise, are appointed by the other enterprise; or (f) more than half of the directors or members of the governing board, or one or more of the executive directors or members of the governing board, of each of the two enterprises are appointed by the same person or persons; or (g) the manufacture or processing of goods or articles or business carried out by one enterprise is wholly dependent on the use of knowhow, patents, copyrights, .....

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re supplied by the other enterprise, or by persons specified by the other enterprise, and the prices and other conditions relating to the supply are influenced by such other enterprise; or (i) the goods or articles manufactured or processed by one enterprise, are sold to the other enterprise or to persons specified by the other enterprise, and the prices and other conditions relating thereto are influenced by such other enterprise; or (j) where one enterprise is controlled by an individual, the .....

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not less than ten per cent interest in such firm, association of persons or body of individuals; or (m) there exists between the two enterprises, any relationship of mutual interest, as may be prescribed. 20. Admittedly, the case of the Revenue authorities against the present assessee is that the assessee which had entered into an agreement for the supply of Nozzle Shroud Plates to Cummins and as per the terms of the said agreement, Cummins was the deemed AE of the assessee before us. The conclu .....

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the Act. The fall out, the assessee having a deemed AE was the reference made to the TPO for determining the arm's length price of international transaction entered into by the assessee and further, as against the year of completion of assessment in the ordinary cases by 31.12.2010, where reference is made to the TPO in respect of determination of arm's length price of international transaction, then the time period for completion of assessment stands extended by one year i.e. by 31.12.2 .....

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between two parties, who are associate enterprises in relation to the other, then international transactions have to be computed having regard to the arm's length price. The meaning of associate enterprise is defined by section 92A of the Act, which recognized not only the associate enterprise but also defines the situation where two enterprises shall be deemed to be associate enterprises. Various situations are enlisted under sub-section (2) to section 92A of the Act and for deciding the p .....

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full control over the management, control and capital of the company. Further, there were no intermediaries in the management, control or capital of the company or business of the company. The assessee company had no third person outside the family members, who were the shareholders or Directors. The shareholders and Directors of the assessee company were not the Directors / Shareholders in any concern, who had any direct or indirect interest in any concern outside India. The assessee further cl .....

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s manufacturing Nozzle Shroud Plates in its unit-3 which was 100% export oriented unit and where the plates were exported exclusively to Cummins and in view thereof, the assessee company and Cummins shall be deemed to be associate enterprises as per the provisions of section 92A(2)(h) and (i) of the Act. It may be clarified herein that though the show cause notice was given in this regard, the CIT(A) has held the assessee and Cummins to be associate enterprises, in view of clause (i) to section .....

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al or the same persons who participate directly or indirectly, or through one or more intermediaries in the management or control or capital of the enterprise. The scope of associate enterprises is enlarged by clause (b), wherein in addition to the one or more persons participating in the management or control or capital of both enterprises and if through one or more intermediaries is also held to be associate enterprises. Clause (2) to section 92A of the Act starts with the Preamble for the pur .....

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1) 47 SOT 252 (Mumbai), wherein it was held as under:- 10. We find that, in terms of the provisions of section 92A(1)(a), the expression 'associated enterprises' refers to an enterprises "which participates, directly or indirectly, or through one or more intermediaries, in the management or control or capital of the other enterprise". The scope of 'associated enterprises' is expanded further by section 92A(1)(b), taking into account group concerns, and it is provided th .....

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e management or control or capital of two or more enterprises, such enterprises are required to be treated as 'associated enterprise'. Interestingly, even as definition of 'associated enterprises' has crucial references to 'participation in management or control or capital' at some places, the precise scope of this expression has not been defined under the provisions of the Income-tax Act, and it has not come up for judicial adjudication either. This expression has been u .....

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trol in decision making process. 11. In our considered view, therefore, the definition of associated enterprises in section 92A(1)(a) and (b ) is, what can be termed as, basic rule. In plain terms, the basic rule is that when one enterprise participates in the control or management or capital of the other enterprise (directly or indirectly or through one or more intermediaries) or when persons participating (directly or indirectly or through one or more intermediaries) in control or management o .....

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e required to be treated as 'associated enterprise'. Section 92A(2) gives practical illustrations of this kind of a control. All these illustrations deal with simple situations of dealing with two enterprise, as envisaged in section 92A(1)(a), but these are equally good for application in situations involving more than two enterprise, as envisaged in section 92A(1)(b). Section 92A(2)(e), for example, refers to a situation in which "more than half of the directors or members of the g .....

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#39;associated enterprises' but when the same basis extends to more than two enterprises, these enterprises will not be associated enterprises. That is clearly an incongruous result. In our considered view, as all clauses of deeming fictions set out in section 92A(2) are only illustration of the manner in which this de facto control on decision making exists, it is necessary that, while interpreting these deeming fictions, we interpret the same in such a manner as to make them workable rathe .....

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respect of which the assessee has exclusive rights. This relationship meets the test of de facto control on decision making as set out in section 92A(2)(g). The assessee in turn, as evident from information in Form 3CEB, is controlled, by way of equity participation, by Diageo PLC which also similarly controls other entities in the Diageo group, including the entities from which CBU has imported the raw materials. Diageo PLC thus, through the assessee as an intermediary, controls the CBU as als .....

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which raw materials were purchased by the CBU. In any case, since the costs of all the raw materials is picked up by the assessee, for all effective purposes, the transaction is actually between the assessee and the Diageo group concerns supplying the raw material to the CBU, and since the assessee as also these vendors are admittedly under the control of Diageo PLC, the transactions are clearly between the associated enterprises. The objection raised by the assessee to the effect that the tran .....

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cases where this situation is not fulfilled, the provisions of Chapter X of the Act are not applicable. Even Article 9 of DTAA between India and USA refers to participation in management or control or capital and where such management, control or capital is missing between two enterprises, they cannot be referred as associate enterprises. 24. Now, coming to the facts of the present case, the assessee is engaged in the manufacture and sale of Nozzle Shroud Plates at unit-3, which is 100% EOU. The .....

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required for one type of Turbo chargers, which was exclusively used in that type of diesel engines. Cummins was manufacturing Turbo chargers required for several types of diesel engines. The total turnover of the assessee for the year was ₹ 48.45 crores, out of which export sales to Cummins was ₹ 9.34 crores i.e. 19.26% of the total sales. Further, the total material consumed for all the products including Shroud Plates was ₹ 24.10 crores and as per the assessee, the correspon .....

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of any engineering changes. In this regard, the assessee has stressed that in assessment year 2007-08, when there was design change made by Cummins, the additional cost for the same was reimbursed by it by way of one time additional cost settlement. Much emphasis has been laid on clause 4.7 of the said agreement, under which it was agreed upon that the supplier i.e. assessee had to offer goods at competitive market rates and in case an alternate supplier was found, who offers more competitive co .....

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merit in the said stand of revenue authorities, where the understanding between the parties is for the purpose of carrying on the business at competitive rates and where there is an alternate provided in the purchase agreement to determine the cost of goods, the same does not lead to the conclusion that the price is controlled by purchaser. The clause itself provides that the current supplier i.e. the assessee would have 30 days time to respond to competitive threat and if he so responds, then, .....

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the entirety of the facts, where the exports to Cummins constitute about 18.76% of the total export turnover, we find no merit in the stand taken by the Revenue authorities. 25. Another aspect to be noted in the present case is that the total turnover of the assessee was ₹ 48.45 crores. However, Cummins Turbo Technologies, USA was a subsidiary of Cummins INC, USA, which is a Multinational Fortune 500 Companies, whose turnover of Turbo chargers was close to about ₹ 3500 crores. In the .....

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ered into any international transactions with any associate enterprises, there is no requirement for making a reference to the TPO in the present facts of the case. Accordingly, reference made by the Assessing Officer though with the prior permission of CIT-III, Pune is not justified since the assessment to be completed in the hands of assessee was a normal assessment, hence the assessment order should have been passed by 31.12.2010. However, the present assessment order having been passed on 30 .....

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