MAHALAXMI CONTINENTAL LIMITED,GUWAHATI vs. INCOME TAX OFFICER (DCIT/ACIT CIR-1), GUWAHATI

In the result, both the appeals of the assessee are allowed

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumar

3. At the time of hearing, the ld. Counsel for the assessee submitted that the AO has no jurisdiction to refer the issue of determination of Arms Length Price of the specified domestic transactions of purchases with the AEs to the transfer pricing officer under clause (i) of u/s 92BA of the Act as the said section omitted with retrospective

MAHALAXMI CONTINENTAL LIMITED,GUWAHATI vs. INCOME TAX OFFICER (DCIT/ACIT CIR-1), GUWAHATI

In the result, both the appeals of the assessee are allowed