TP adjustments - reference made to TPO - Cognizance u/s 92BA(i) ...

Income Tax

May 26, 2023

TP adjustments - reference made to TPO - Cognizance u/s 92BA(i) - effect of omission of law - undisputedly, by the Finance Act, 2017, clause (i) of section 92BA has been omitted with effect from 01.04.2017, therefore, once this clause is omitted by subsequent amendment then it would be deemed that clause (i) was never there in the Statute. Therefore, we hold that the reference made to TPO under section 92CA is invalid and bad in law and hence consequential order passed by the TPO and AO is also not sustainable in the eyes of law - AT

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TP adjustments - reference made to TPO - Cognizance u/s 92BA(i) ...

Income Tax

May 26, 2023

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