In the result, the Revenue’s appeal as well as Assessee’s appeal are partly allowed for statistical purposes
15A. The learned Assessing Officer has erred in making a reference to the TPO without recording a finding that he considers it 'necessary or expedient' to do so as required under section 92CA(1) of the Act, hence the reference made by the Ld AO to TPO suffers from jurisdictional error. 15B. The Learned AO has erred in not granting