SARASWATI AGRO CHEMICALS (INDIA) PVT. LTD,MOHALI vs. DCIT, CIRCLE-6(1), MOHALI

In the result, the transfer pricing adjustment so made by the AO and confirmed by the ld CIT(A) amounting to Rs 89,22,420/- is hereby set-aside and the ground of appeal is allowed

Bench: Or At The Time Of Hearing.”

40A(2)(b) of the Income Tax Act, 1961 then these are to be construed as Specified Domestic Transactions and reference to TPO and subsequent adjustment is justified. It was submitted that anything emanating from assessment records can be considered at any stage by Ld. A.O or Worthy CIT(A) when question of law is involved whether it is right