TMI BlogTP Adjustment - The Appellate Tribunal considered the amendment made to the section, which specified...TP Adjustment - The Appellate Tribunal considered the amendment made to the section, which specified domestic transactions exceeding a certain threshold. The Tribunal noted that the transactions in question were not international transactions and did not fall under the ambit of Section 92BA. Consequently, it deemed the upward adjustments made by the Assessing Officer invalid. - Delving into the effect of the omission of Section 92BA from the statute, the Tribunal cited legal principles indicating that when a provision is repealed, it should be considered as if it never existed. Therefore, the Tribunal reasoned that the decision made by the Assessing Officer based on Section 92BA was without jurisdiction and liable to be quashed. ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
